ML20215J774
| ML20215J774 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/19/1987 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#287-3830 OL, NUDOCS 8706250107 | |
| Download: ML20215J774 (36) | |
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- hM I kKATED CORMESPO$M 3
Filed: JuneElh 1987
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. UNITED STATES OF AMERICA l NdCLEAR: REGULA' TOR'? ' COMMI SSION '07 JUN 22 P2 :29 O
before the'-
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ATOMIC. SAFETY AND LICENSING BOARD BRN 1
)
[d-In the' Matter of
)
Docket Nos. 50-445-OL c'
-)
50-446-OL 1
ll.e TEXAS. UTILITIES GENERATING'
)
COMPANY et:a1.
)
L
}-
(Application for an (Comanche Peak Steam' Electric
)
Operating' License)
Station, Unite 1 and 2).
i..
)
)
)
APPLICANTS' INTERROGATORIES-TO INTERVENOR.
(Set No.'1987-9)
Pursuant'to 10 C.F.R.
$ 2.740 ff the Applicants hereby i
. propound the following interrogatories to Intervenor CASE.
Definitions As used in these Interrogatories, the following terms have the following. meanings:
l
" Litigate" with regard to a topic or contention means to offer direct testimony relating to, to cross-examine on, to uh,.
offer' proposed findings or rulings regarding, or to urge the p.
't
. denial-(or allowance subject to conditions) of the pending
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-application on the basis of, the topic or contention in question.
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" Identify"Lwith respect to an' expert witness means to t
state:
_(a).
The'name, mailing address,. age and present L
professional.or employment affiliation of the person; (b).The profession or occupation and field of claimed-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; i
l (d)
The history of specialized training in the area of
_ l claimed ~ expertise, including, but not limited to, (i) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; i
(e)
The history of membership of the person in any professional or trade association in the area in i
the claimed expertise, including, but not limited to, (i) the name of each professional or trade association, (ii) the dates of membership, and l
a s
L*
(iii)la description'of each office held in each
> association; p
(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 designationiof 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 byfwhich these i -
requirements were met; (h)
The amount of time the person has-worked in the I
field of claimed expertise, stating periods where work was other than-on a full-time' basis;
.( 1)
The name and address of every person, or every i
corporation or other institution, that has employed
-j i
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
1 (k)
All previous experience in the field of claimed
>'L expertise which involved problems,. analyses or n
studiesEsimilar to.those concerning which the personLis' 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
)
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 I
unqualified negative, you may proceed to II-1).
)
Seven of those splices (discussed at page 16, ISAP I.a.2) that had been heat-shrunk were noted as having insulation damage.
It appears that these splices were overheated causing a slight split in the sleeve of the I
splice at a point of crimping-induced stress.
In all seven cases the wire barrel and conductors were still 1 {
j J
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protected. 'The damage.would'not have affected the-intended' safety' function of the splices.
(Results Report, ISAP"I.a.2, page 17).
I-2.
Please state.each and'every respect in which CASE
Elsagrees.with the above statement.
4
.(a) 6n~vhat specific facts'does CASE base'its disagreement?'
(b)
Identify the documents upon which CASE will rely 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 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 cf'the facts toLwhich each expert witness is expected to testify; I
(iii) state the substance of the opinion or opinions to'which each expert witness is expected to testify; I
(iv) provide a summary of the grounds for each opinion to which each expert witness is q
expected to testify;
)
i i
r
~4a (d). Does the.Intervenor disagree with the above statement due'to the methodology-through which the
?
statement's conclusions were reached?
If-so, please state-the precise manner in which the methodology was flawed..
-(e)
Does the Intervenor disagree with the above statement due.ia) 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.
'l 4
I-3.
Prior to answering this' set of Interrogatories, i
has the Intervenor-reviewed the Working File for the Results 1
Report in question?
l I-4.
Has the Intervenor propounded any Interrogatories.
f regarding the Results Report in question in order.to obtain any information it believes to be necessary so as to make i
- its review-of the Working; File complete?
II-1. 'Does the Intervenor intend to litigate the I
validity of the conclusions expressed in the following statement?-' (If the answer t'o this Interrogatory is an unqualified negative, you may proceed to III-1.)
[F]ew, if any, unauthorized splices exist in [the]
panels [ discussed in ISAP I a.2,-$5.2.5].
(Results Report, ISAP I.a.2, page 21).
) 1
II-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
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, 4
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 precise manner in which the methodology was i
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
'l III-1.
Does the'Intervenor intend to litigate the
-validity of the conclusions.. expressed in the following l
l statement?
(If your' answer is an unqualified negative you j
l may proceed to IV-1.)'
.1
.Because all cases where one strand was missing had acceptable pullout forces, the definitive worst case was l-
~ detected during reinspection, the post ~ installation
[
inspection process is considered to be an acceptable p
screen for splice quality.
(Results Report, ISAP I.a.2, page 21)
~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 3
I statement, or any portion thereof, i
(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) l with regard to their proposed testimony.
1 (d)
Does the Intervenor disagree with the above statement due to the methodology through which the statement's conclusions were reached?
If so, state
~
)
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- - - - - -.. -... -- _.. )
(
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 l
reached?
If so, state the precise manner in which the. implementation was flawed.
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).
l
[The] data [ discussed at ISAP I.a.2, page 22] suggests that insertion depths of the remaining AMP PIES splice l
installations were likely to be acceptable. (Results I
Report, ISAP I.a.2, page 22).
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 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 validity of the conclusion reached in the above statement?
l-l L
9_
....... -. ~
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.
u 1
l V-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer is an unqualified negative, you may proceed to VI-1).
The results of the[] activities [ described at ISAP.
I.a.2, page 23] demonstrated that there is reasonable assurance that the AMP PIES splice installations in
]
electrical panels at CPSES are capable of performing their intended safety function.
(Results Report, ISAP
{
I.a.2, page 23).
l V-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?
o l
I j
1 J
(b)
Identify the documents Intervenor will rely upon to l
l i
sustain its position of disagreement, or any portion thereof.
i (c). Does the Intervenor intend to offer the testimony of any expert witness with respect to theLabove 1
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 l
reached?
If so, state the precise manner in which the implementation was flawed.
VI-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer is an unqualified negative, you L
may proceed to VII-1).
Though the destructive pullout forces of the sample did not conform closely to that of a normal distribution, the strengths of all the tested splices were so many times greater than the maximum expected force at CPSES that the probability of a deficient splice existing in..
1 t-l the balance of the population must be negligibly small.
i (Results Report, ISAP I.a.2, page 24).
L VI-2.
Please state each and every respect in which the i
.Intervenor disagrees with the above statement.
j (a)
On what specific facts does the Intervenor base its l
1
(
disagreement?
l (b)
Identify the documents Intervenor will rely upon to j
l sustain its position of disagreement, or any portion thereof.
l (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, i
please answer all Interrogatories I-2(c)(i) -
f l
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above L
i' j
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 I
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 statement below?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to VIII-1.)
j j
f For [ISAP I.a.2] Phase I and II findings, the testing and analysis performed by the CPSES Project and SWEC has
)
demonstrated that the AMP PIES splices would have i
performed their intended functions.
(Results Report, i
ISAP I.a.2, page 26).
VII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
l (a)
On what specific facts does the Intervenor base its l
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 1
1 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 flawed.
(e)
Does the Intervenor disagree with the above _
I statement 1due 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.
j I
i VIII-1.
Does the Intervenor intend to litigate the i
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.)
J
'Despite various breakdowns in engineering, craft, and QC I
that occurred, the testing and analysis discussed in this report demonstrated that the splices reviewed in Phases.I and II would have been able to perform their
' intended function.
(Results Report, ISAP I.a.2, page 32).
l VIII-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 i
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, 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 the statement's conclusionL were reached?
If so, please 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.
IX-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 X-1.)
The untimely detection of test data failing to meet stated acceptance criteria was, [with regard to inverters], of minor significance from a safety l
point-of-view.
'(Results Report, ISAP III.a.5, page 15).
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. -
l (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) -
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 l
conclusions were reached?
Tf 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.
IX-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?
IX-4.
Has the Intervenor propounded any Interrogatories j
1 regarding the Resulth 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?
X-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following l J
r statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XI-1.)
[A] similar failure to provide adequate test data scrutiny is unlikely to have occurred elsewhere and that the subject case is not typical of the performance of the JTG and STEs on the CPSES Test Program.
(Results Report, ISAP III.a.5, p.16).
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.
(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.
j a
(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
' I
reached?
If so, state the precise manner in which the implementation was flawed.
XI-1.
Does the Intervenor intend to litigate the I
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.)
A review of all the preoperational testing work of the STEs involved indicates that [their work) was performed in a satisfactory manner.
(Results Report, ISAP III.a.5, p.16) i XI-2.
Please state each and every. respect in which the i
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 precise manner in which the methodology was flawed.
1 (e)
Does the Intervenor-disagree with the above i
I statement due to the actual implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise I
manner in which the implementation was flawed.
l l
XII-1.
Does the Intervenor intend to litigate the i
l validity of the conclusions expressed in the following j
statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XIII-1.)
j i
'A review of'the administrative procedures and I
supplementary instructions. indicates that they provide adequate guidance to the personnel-involved.
(Results Report, ISAP III.a.5, page 11).
L 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 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, 1
1.
l
- s. :
m 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 wh'ch its i
P conclusi'ons were reached?
If so, state the' precise manner in which the: methodology was flawed.
I (e);. Does the;Intervenor disagree with'the above w.
~
statement due to the implementation of the action plan through which the statement's' conclusions were l
i
' reached?L If so, state the precise manner in which LtheI1mplementation was flawed XIII-1.
Does;the Intervenor intend to litigate the.
validity of't - conclusions expressed in;the following statement?
g f your answer to'this Interrogatory is an unqualified negative, you may' proceed to XIV-1;)
The' root cause.of the failure to identify unacceptable
' test data was that the process, as implemented,
- permitted.the acceptance criterion and implementing 4
instructions to be stated in the procedure in-a sufficiently. ambiguous manner that reviewers did not anticipate the misinterpretation adopted by the I'l performer and that recorded data outside=the limits of acceptability were not readily apparent.
That is, had 1
the 1CP-PT-02-02 test procedure been written in a format similar to the majority of procedures developed at
.i CPSES, with the range of acceptable inverter output l
voltage'specified, the process, as implemented, would have insured detection and resolution of the unacceptable test data.
.(Results Report, ISAP.III.a.5, page 16).
XIII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement. !
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 I
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 4
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.
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 an unqualified negative, you may proceed to XV-1.)
The RTL concluded that there is reasonable assurance that the acceptance criteria in the preoperational test...
}
t
. data packages have, in fact, been reviewed and approved according to the Startup Administrative' Procedures, that
~
the requirements in the-Startup Administrative Procedure are' adequate to accomplish the review and approval process,. and that the acceptance criteria-in the Unit l' preoperational test data packages have been met.
(Results Report, ISAP'III.a.5, page 17).
)
.)
1 XIV-2.
Please state each and every respect in which;the i
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.
]
i 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( )(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 plan through which the statement's conclusions were i
. reached?
'If so, state the manner in which the i
implementation is flawed.
.XV-1.
Does the Intervenor' intend to. litigate the I
validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory.is an unqualified negative, you may proceed to XVI-1.)
i The inverter's performance was acceptable based on the' original test, and would not have posed any significant safety concern for the equipment powered by the inverters even if the failure to meet the stated acceptance criteria had not been detected.
(Results-Report, ISAP III.a.5, page 17).
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.
(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 9
$SE
' conclusions.were. reached?- If so, state the precise I
manner in which the methodology was flawed.
~
.(e)
Does the Intervenor disagree with th'e 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.
XVI-1.
Does the Int.*venor 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 XVII-2.)
Sufficient measures have been established to preclude occurrence (of acceptance of test data not in conformance with CPSES criteria} in the future.
(Results Report,.ISAP III.a.5, page 18).
XVI-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?
l (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,
, )
I
c.
- -=
P.
please answer all1 Interrogatories I-2(c)(1)
I-2(c)(iv) with regard 1to 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.
XVII-1.
Does the-Intervenor intend to' litigate'the validity,of the conclusions expressed in the following statement?
(~If your answer is an unqualified negative,.you.
may proceed to.XVIII-1.)
(T]he (Hot Functional] test results are acceptable, and the cooling requirements.for Unit.1 have been satisfied, provided that the Technical-Specifications are~ changed to: provide'a limit of 150'F for the exit air temperature.
(Results Report, ISAP VI.a, page 14)'.
XVII-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 s
disagreement?
-(b)
Identify the documents Intervenor will rely upon to l
l l J
L
l 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 i
conclusions were reached?
If so, state the reasons why the methodology was flawed.
l i
(e)
Does the Intervenor disagree with the above i
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.
XVII-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?
XVII-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?
XVIII-1.
Does the Intervenor intend to litigate the i
e LC
, validity of the. conclusions expressed in the following statement?-
(If your answe" to this Interrogatory is an unqualified negative, you riay proceed to XIX-1. )
The calculations [ISAP VI.a, Reference 9.15]' demonstrate the adequacy of the cooling system.
Based on these.
calculations, the configuration of the Unit 2 cavity and the success of the Unit I retest under hot functional conditions, it is expect.ed that Unit 2 will also meet its HFT performance reuirements.
(Results Report, ISAP VI.a, page 16).
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 cf 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, please answer all Interrogatories I-2(c)(i) l I-2(c)(iv) with regard to their proposed testimony.
i i
(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
0 (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.
XIX-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 1
unqualified negative, you may proceed to XX-1.)
From a programmatic perspective, the scope of process
[used at CPSES to identify and resolve adverse interactions between non-nuclear safety and safety related items) was considered adequate in that the program elements [ discussed at ISAP VI.a, page 18]
l encompass all the methods necessary to address these i
interactions.
(Results Report, ISAP VI.a, page 18).
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?
l i
(b)
Identify the documents Intervenor will rely upon to j
sustain its position of disagreement, or any portion thereof.
l (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,
)
n.
1
^
e, Leonclusions were reached?
If so, state the reasons I
' 4 b
.g hh, y
why the' methodology was flawed.
i'
^'
.(
. (
(e), ?)oes'the Intervenor,dinagree with the above t-
)
k'f-
. K/:
yl.
statement due to the implementation of,the action
,(
- 'f plan 'through which the sta';ement's conclusions were reached?.
If so,' state the reasons why the y
U mplementation was flawed.
1 i
1 r.1 4
[h DoestheIntervenor$Etendto'litigatethe
.XX-1.
- , s
. s h
,z validity of the conclusions exprebsed in the following
(
.L
[
statement?
(If your answer to this Interrogatory is an I>
s unqualified negative,;you'may proceed to XXI-1.)
ky o
[T]he implementation of d41tidiscipline engineering 1
reviews has been a bauf,.cgfunction with CPSES design process since the beginning [of the project}.
(Results Report, ISAP VI.a, page 24).
j, f
XX-2.
Please state each and every respect in which the 1
h Intervenor disagrees with the above statement.
- t.,.
.t.
,t.-
,1 N'
it (a)
On what specific facts does the Intervenor base its
{f disagreement?
1
- 3,
1 (b)
Identify the documents Intervenor will rely upon to 29 -
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i 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 is flawed.
XXI-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 XXII-1.)
Review of a representative sample of DCAs and CMCs.
provide an effective test of the implementation of the NNS design charge process.
(Result Report, ISAP VI.a, page 24).
XXI-2.
Please state each and every respect in which the Intervenor disagrees with the above statement. )
A
'(a) on what specific facts does the Intervenor base its disagreement?
( b )'
JIdentify 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 Interrogacor.4 es 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 reason why the implementation was flawed.
XXII-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 XXIII-1.)-
[Tho] procedural changes [ discussed in 6 5.4.2 of ISAP VI.a] will enhance the Interdisciplinary Review process i
in its ability to detect and prevent adverse i
interactions that may be caused by NNS design changes.
(Results Report, ISAP VI.a, page 31).
XXII-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.
I (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. 4
XXIII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following i
statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIV-1.)
Result [s] from the sampling investigation, in concert with the thoroughness of the scope of hardware and design evaluations provided by the CPRT yields reasonable assurance that NNS design charges have not adversely affected safety-related systems (Results Report, ISAP VI.a, page 31).
XXIII-2.
Please state each and every respect in which the i
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 the statement's conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
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 the precise manner in which the implementation was flawed.
TEXAS UTILITIES ELECTRIC COMPANY l
For the Owners of CPSES l
6
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l Thomas G.
Dignan, Jr.
l R.
K.
Gad III William S.
Eggeling Jeffrey H. May ROPES & GRAY 225 Franklin Street l
Boston, Massachusetts 02110 Telephone:
(617)423-6100 Attorneys for Texas Utilities Electric Company I
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1 1
A b
00f. K!* Til C -- l R l' CERTIFICATE OF ' SERVICE
'87 JW 22 P2 :29 I, Robert K. Gad III, hereby certify that on June 19, 1987, I 0F? n s
made' service of." Applicants' InterrogatoriesT$iMterveSo'r-(Set No.
0 I
1987-9)" by mailing copies thereof, postage prepaid, to:
l Peter B. Bloch, Esquire
.Mr. James E. Cummins Chairmani 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 l
Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge GAP-Midwest Office 881 W. Outer Orive-104 E. Wisconsin' Ave.
B Oak Ridge. T-ane s see 37830 Appleton, WI 54911-4897 j
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 Lawrence J.
Chandler, Esquire Mrs. Juanita Ellis J
Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S.. Nuclear Regulatory Dallas Texas 75224 1
Commission Washington, D.C.
20555 i
i
Renea Hicks, Esquire Ellen Ginsberg,. Esquire Assistant Attorney General-Atomic Safety and Licensing Environmental. Protection Division
. Board Panel i
L P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission IF Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire.
Mr. Lanny A.
Sinkin Suite 600 Christic Institute f
1401 New York Avenue, N.W.
1324 North Capitol Street Washington, D.C.
20005 Washington, D.C.
20002 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, Esq.
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 Washington, D.C.
20555 Nancy H. Williams 2121 N. California Blvd.
Suite 390 Walnut Creek, CA 94596
\\
/
R.
K. Gad III l
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________________________________________________________________________J