ML20212R621

Supplemental Staff Answers to Case Interrogatories.* Suppls 861205 Answers to Case 860922 Discovery Request & Interrogatories 2,4 & 8.Affidavit & Certificate of Svc Encl. Related Correspondence

ML20212R621
Person / Time
Site:	Comanche Peak
Issue date:	01/27/1987
From:	Bachmann R NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Citizens Association for Sound Energy
References
CON-#187-2362 OL, NUDOCS 8702030008
Download: ML20212R621 (7)

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. January 27p01987ED uwc UNITED STATES OF AMERICA '87 JAN 30 P4 :31 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARDIf,,'t In the Matter of )

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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 -() b COMPANY, et al. ) 50-446

) .

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

SUPPLEMENTAL STAFF ANSWERS TO CASE'S INTERROGATORIES On December 5,19E6, the Staff filed "NRC Staff Answers to CASE's Interrogatories and Requests for Production of Documents" (Staff Ans y'ers) , in response to CASE's September 22, 1986 discovery request

, "CPRT Discovery-Staff." Following subsequent discussions with counsel

! for intervenor CASE, the Staff has agreed to supplement the answers previously provided to CASE's Interrogatories 2, 4 and 8. Accordingly, the following supplemental answers are submitted on behalf of the Staff.

1 See attached Affidavit of Charles M. Trammell, III.

INTERROGATORY 2 This interrogatory requested information concerning each inspection, review or other activity that evaluated the CPRT program plan. The Staff had previously objected to the interrogatory to the extent that it requested information on (1) evaluations of the implementation of the program plan, and (2) internal Staff meetings, discussion sessions or work activities regarding program plan adequacy. Counsel for CASF did 1

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not dispute the former objection. As to the latter, the Staff supplements

> f ts prior answer as follows:

The Staff has conducted numerous internal meetings with respect to the adequacy of the CPRT program plan as it relates to construction.

Ilowever, neither the subject matter discussed nor the personnel in attendance were documented, nor is it possible to identify the dates of such meetings or discussions.

INTERROGATORY 4 This interrogatory requested an explanation of the process by which the Staff "overviewed" the CPRT program plan. The Staff objected to the interrogatory as being vague, since the meaning of the term "overviewed" could not be determined. The Staff also objected to the extent information was sought concerning the evaluation solely of the program plan implementation; this latter objection was not disputed by counsel for CASE. After the aforementioned discussions with counsel for CASE regarding the term "overviewed", the Staff supplements its prior answer as follows:

The overall description of the Staff's evaluation of the CPRT program plan adequacy is found in SSER 13. The CPRT program plan " overview" (review) included numerous audits and inspections conducted primarily in the summer and fall of 1985 (See, e_.g_. , Memorandum from E.B. Tomlinson to J. Calvo, " Report of Site Audit of CPRT Self-Initiated Construction Adequacy Program -

October 1985", dated May 15, 1986, which is part of Attachment I to tne December 5, 1986 Staff Answers). To the extent that the Staff had concerns regarding the adequacy of the plan which require a review of some part of the plan implementation, those concerns are enumerated in Appendix B of SSER 13. The general matters identified in paragraph B.1 of Appendix B will be reviewed by audits and inspections, except for item B.1(8). For example, Toledyne has already

o performed some assessments for the Staff, as documented in a Teledyne letter from D.F. Landers to I. Barnes, NRC Region IV dated July 1,1986, which is part of Attachment 2 to the December 5, 1986 Staff Answe/s. Item B.1(8) was resolved by a submittal from the Applicants dated July 23, 1986; the Staff review is documented in an NRC letter from V. Noonan to W. Counsil, TUGCO, dated January 13, 1987, a copy of which was sent to all parties. Other items identified in Appendix D will be reviewed both by audits and inspections and by a review of the relevant ISAP and/or Results Report.

IllTERROGATORY 8 This interrogatory requests the identity of all inspectors and consultants

" currently assigned to the Comenche Peak project". The Staff objected to the interrogatory in its entirety, since it appeared to relate only to the implementation phase of the CPRT program plan. After discussions with counsel for CASF concerning the scope of the interrogatory, the Staff supplements its prior answer as follows:

Limiting this response to those involved in the review of the adequacy of the program plan as applied to construction, the Staff's principal inspectors and consultants currently involved with Comanche Peak are as follows:

NAME AREA OF REVIEW I. Barnes supervisor P. Wagner electrical L. Ellershaw mechanical, civil / structural C. Hale QA/QC D. Jeng civil / structural S. Hou mechanical, piping / supports J. I: night electrical D. Tereo piping / supports G. Bagchi mechanical piping / supports

4-l Consultants

h. RIasterson mechanical, piping / supports V. Ferrarini mechanical, piping / supports, civil / structural D. Landers mechanical, civil / structural J. Rivard civil / structural L. Stanley electrical /I&C R. Hookway piping /rupports B. Saffell mechanical, piping / supports C. Hofmeyer civil / structural R. Philleo civil / structural J. Malonson QA/OC P. Chen mechanical, piping / supports J. Flaherty civil / structural Respectfully submitted C

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Richard G. Bachmann Counsel for NRC Staff Dated at.T1cthesda, Maryland this gNday of January,1987 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 COMPANY, et _al. _

) 50-446

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

AFFIDAVIT OF CIIARLES M. TRAMMELL III I, Charles M. Trammell III, being duly sworn, do depose and state the following:

1

1. I am a Senior Project Manager in Project Directorate No. 5, Division of PWR Licensing - A, Office of Nuclear Reactor Regulation. A copy of my professional qualifications has been previously supplied.

2. I was responsible for providing supplemental answers to Interrogatories 2, 4, and 9 in CA SE's September 22, 1986 "CPRT Discovery-St aff. "

The statements above are true and correct to the best of my current knowledge and belief.

k. / rhsr ll, Charles M. Trammell III Subscribed nd sworn to before me this J 7 of January,1987 J /h e .

COX44 Notary Pub]}d L My commission expires: .Tuk l. M O O

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1 UNITED STATES OF AMERICA '2il M N NUCLEAR REGULATORY COMPIISSION 3..r

" "1 BEFORE TIIE ATOMIC SAFETY AFD LICENSING BOAND - -

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In the Matter of )

)

TEXAF UTILITIES ELECTRIC ) Docket Nos. 50-445 COMPANY, ET AL. ) 50-446

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) ) -

CERTIFICATE OF SERVICE I hereby certify that copies of " SUPPLEMENTAL STAFF ANSWERS TO CASE'S INTERROGATORIES" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an esterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by two asterisks, via express mail, this 27th day of January,1987:

Peter B. Bloch, Esq. , Chairman

• Mrs. Juanita Ellis Administrative Judge President, CASE Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Commission Dallas, TX 75224 Washington, DC 20555 Renea Hicks, Esq.

Dr. Kenneth A. McCollom Assistant Attorney General Administrative Judge Environmental Protection Division 1107 West Knapp P.O. Box 12548, Capital Station l Stillwater, OK 74075 Austin, TX 78711 Elizabeth B. Johnson Nicholas S. Reynolds, Esq.

Administrative Judge William A. Horin, Esq.

Cak Ridge National Laboratory Bishop, Liberman, Cook,

! P.O. Box X, Building 3500 Purcell & Reynolds

Oak Ridge, TN 37830 1200 17th Street, N.W.

I Washington, DC 20036 Dr. Welter II. Jordan Administrative Judge Joseph Gallo, Esq.

881 W. Outer Drive Isham, Lincoln a Beale Oak Ridge, TN 37830 Suite 1100 1150 Connecticut Avenue, N.W.

Washington, DC 20036 I

a Billie Pirner Garde ** Mr. W. G. Counsil Trial Lawyers for Public Executive Vice President Justice Texas Utilities Generating Company 3424 North Marcos Lane 400 North Olive Street, L.B. 81 Appleton, WI 54911 Dallas, TX 75201 William L. Brown, Esq. Anthony Z. Roisman, Esq.

U.S. Nuclear Regulatory Commission Trial Lawyers for Public Justice 611 Ryan Plaza Drive, Suite 1000 2000 P Street, N.W. , Suite 611 Arlington, TX 76011 Washington, DC 20036 Robert A. Wooldridge, Esq. Roy P. Lessy, Jr. , Esq.

Worsham, Forsythe, Samples Wright & Talisman, P.C.

& Wooldridge Suite 600 2001 Bryan Tower, Suite 2500 1050 17th Street, N.W.

Dallas, TX 75201 Washington, DC 20036-5566 Mr. Harry Phillips William H. Burchette, Esq.

Resident Inspector / Comanche Peak Mark D. Nozette, Esq.

Steam Electric Station Heron, Burchette, Ruckert c/o IT.S. Nuclear Regulatory Commission & Rothwell, Suite 700 P.O. Box 30 1025 Thomas Jefferson Street, N.W.

Glen Rose, TX 76043 Washington, DC 20007 Lanny Alan Sinkin James M. McGaughy Christic Institute GDS Assoc. Inc.

1324 North Capitol Street 2525 Cumberland Parkway, Suite 450 Washington, DC 20002 Atlanta, GA 30339 Robert D. Martin Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Board Panel

• 611 Ryan Plaza Drive, Suite 1000 U.S Nuclear Regulatory Commission Arlington, TX 76011 Washington, DC 20555 Robert A. Jablon, Esq. Atomic Safety and Licensing Appeal Spiegel & McDiarmid Board Panel

• 1350 New York Avenue, N.W. U.S. Nuclear Regulatory Commission Washington, DC 20005-4798 Washington, DC 20555 Thomas G. Dignan, Esq. Docketing and Service Section*

Ropes & Gray Office of the Secretary 225 Franklin Street U.S. Nuclear Regulatory Commission Boston, MA 02110 Washington, DC 20555 i

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f ichard~G. Bachmann Counsel for NRC Staff I

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