ML20024E568

Notice of 830822 Deposition of Quadrex Corp on Written Interrrogatories.Certificate of Svc Encl.Related Correspondence

ML20024E568
Person / Time
Site:	South Texas
Issue date:	08/08/1983
From:	Berwick B TEXAS, STATE OF
To:
Shared Package
ML20024E563	List: ML20024E562 ML20024E568
References
ISSUANCES-OL, NUDOCS 8308150308
Download: ML20024E568 (7)

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UNITED STATES OF AMERICA O NUCLEAR REGULATORY COMMISSION DOCKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOM3(6C In the Matter of S ',8 AUG 12 P4:08 S

HOUSTON LIGHTING & POWER COMPANY, ET AL. S Docket Nog 5f@y4M.. OL T' 00Ch50 g gf0 W (South Texas Project, Units S 1 and 2) S STATE OF TEXAS'S NOTICE FOR DEPOSITION OF QUADREX CORPORATION [

ON WRITTEN INTERROGATORIES ,

9 To All Parties:

Please take note that the deposition on written interroga-tories of Quadrex Corporation, 1700 Dell Avenue, Campbell, California, will be taken before the officer whose name, des- -

cription, title and address are shown on Exhibit 2 attached to ~

this Notice.

The deposition will be taken on August 22, 1983. g The questions that will be posed by the State of Texas at the s N

deposition are the ones shown on Exhibit 1 attached to this M Notice. j$

f El Respectfully submitted,  :=c EZ JIM tiATTOX .b Attorney General of Texas IEE DAVID R. RICHARDS Executive Assistant Attorney $

General *

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JIM MATHEWS Es; Assistant Attorney General 5E Chief, Environmental Protection i Division $

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Assistant BERWICK Attorney (SBN General 02258500).

Environmental Protection Division P. O. Box 12548 Austin, Texas 78711

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i Exhibit 1 QUESTIONS TO BE ANSWERED BY QUADREX CORPORATION l

1.

! Please provide copies of brochures or other material used by the Quadrex Corporation as of January 1, 1981 to des-cribe Quadrex's work, capabilities, etc. to potential clients.

i 2.

Please define the term " technical adequacy or inadequacy" as I, Section 1.0, used by Quadrex pagein 1-2.

the Quadrex/STNP study of May 1981, Volume j

1 3.

i At the time Quadrex performed the STNP study, why did

! Quadrex tory Commission? not evaluate what was reportable to the Nuclear Regula-i 4.

}

Please identify the Quadrex employee in charge of each discrete evaluation area in the Quadrex Report, e.g. Civil /  !

Structural, Mechanical, Electrical, etc.

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5. E Who coordinated the entire audit for Quadrex? E.

6. 5 which so, why?

had not yet been released for use by construction?Did If the E E

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7.

Please explain the relationship between the Nuclear 5_

Services Corporation and the Quadrex Corporation [

a. prior to January 1, 1981 5

b. $

in the period January 1, 1981 through May 7,

c. after May 7, 1981 9 1981 ~

w 8.

Based on what Quadrex knows now, I the' generic Quadrex Corporation would make in any finding,are thereincluding any changes @.

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finding, in the Quadrex Report? *

9. ~

Please identify those generic findings which Quadrex IE E

believes are unsupported by the underlying data. EE

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10.

Regarding the Bechtel reviews of the Quadrex Report:

on the Quadrex a. HasReport? Quadrex reviewed the March 1982 Bechtel report E Report referred b. HastoQuadrex as EN-619? reviewed the Bechtel review of the Quadrex $

c.

Please id'ntify e and provide copies of any documents h which record the Quadrex responses &

d.

Please detail any points tointhe two the Bechtel Bechtel reviewsreviews. -

gj with which Quadrex disagrees. gg

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.11 Finding 3.l(a) of the Quadrex Report states t " Assigned responsibility for systems engineering is only a- recent develop-ment."

'h; a. Does this sentence refer to the Brown and Root System Design Assurance Group? If not, please explain the "recer.l,t development. "

b. Is it correct that Quadrex reviewers did not talk to membe'rs of the B&R System Design Assurance Group?

, c. If the answer to interrogatory 11b is "yes," please explain why Quadrex reviewers did not talk to this group. ,

. . d. Based on what Quadrex knows now, does Quadrex '

take the position that the B&R Systems Design Assurance Group did have responsibility for systems integration and overview in the January-May, 1981 period?

, e. Based on what Quadrex knows now, is it the position of Quadrey, that ,the B&R System Design Assurance Group constituted and "ef fective systems integration and overview function" within the B&R design process? (Finding 3.l(a)) Please explain your answer.

'12. In the first Bechtel assessment of the Quadrex Report

("An Assessment of the Findings in the Quadrex Corporation Report dated May 1981" issued by Bechtel in March 1982) the Bechtel reviewers state: "there also existed a Physical Design Assurance Group." (at 2-8) s

a. Did Quadrex reviewers talk to members of this Physical Design Assurance Group?

b. - If: the answer to interrogatory 12a is "no,," please explain why not.

c. Based on what the Quadrex Corporation knows now, is it the position of the Quadrex Corporation that the B&R P,hysical Design Assurance Group had responsibility for systems integration and overview in the January:May, 1981 period?

d. Based on what the Quadrex Corporation knows now, is 'the position of the Quadrex Corporation that the B&R Physical 4

Design Assurance. Group constituted an " effective systems inte-gration and overview function" within the B&R design process?

(Quadrex finding 3.l(a)) ~

s x 13. Referring to the Quadrex rankings. "Most Serious" etc.-:

a. How were these rankings chosen? s

b. Please identify and provide all correspondence or other record of communication between HL&P and Quadrex regarding selection of the ranking categories.

c. For the "Most Serious" ranking, please explain what Quadrex meant by: -

' (1) "the finding would prevent the obtaining of s a' license" (2) "the finding would produce a significant-

[ delay in getting a license"

. (3) "the finding addresses a matter of serious concern to the NRC at this time." 3 (

14. Did Quadrex use the. term." generic" to indicate the particular problem identified as generic could exist in designs already released for construction, and/or ~could exist in con-struction already completed? 7

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15. Does Quadrex agree with the following statements?:

"The significance of the generic ' findings turns entirely on the nature of the underlying discipline finding." "The discipline findings did not indicate that 'the design was deficient but I rather that Brown & Root was having difficulty in completing the engineering process." Please explain any agreement or

! disagreement.

16. Why did Mr. Stanley assume that the Quadrex Report would be provided to the NRC soon af ter it had been given to HL&P? (Statement to the NRC. )

17. Did the Quadrex Corporation at any time communicate with the NRC regarding the findings of the Quadrex Report prior to August 1981? If so, please identify the persons who communi-cated with the NRC and-the substance of their communication.

Please produce any documentation of those communications.

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Exhibit GA-The deposition officer will be Valerie A. Fitch.

This person is a certified shorthand reporter and notary public in and for the State of California, County of Santa Clara.

This person's work address, and the place where the deposi-tion will be taken, are:

586 North First St.

Suite 240 San Jose, CA 95112 .

The date and time of the deposition will be August 22,

, 1983, at 9:00 o' clock A.M.

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' KFETY AND LICENSING BOARD CERTIFICATE OF SERVICE I hereby certify that copies of St. of Texas's Notice For Deoosition of Quadrex Corporation. on Written Interrogatories 6.d Ifd2 'T [h4 J5df o-%L were served by deposit in the United States Mail, first

.at.d entities on theclass postage paid to the following individuals FM T /) except that service on the single-asterisked people was by, day ofy l federal express and on double asterisked people was by hand.

f Charles Bechhoefer, Esq. William S. Jordan, Esq.

Chief Administrative Judge Harmon and Weiss Atomic Safety and Licensing 1725 I Street, NE Board Panel Suite 506 U.S. Nuclear Regulatory Commission Washington D.C.

Washington D.C. 20006 20555 g/ Jack R. Newman, Esq.

gp Dr. James C. Lamb, III Lowenstein, Newman, Reis &

Adminstrative Judge Axelrad 313 Woodhaven Road 1025 Connecticut Avenue, N.W.

Chapel Hill, NC 27514 Washington D.C. 20036 Ernest E.~ Hill Administrative Judge yp-Robert-G. Perlis -

Lawrence Livermore Laboratory Office of the Executive Legal Director University of California P.O. Box 808, L-123 U.S. Nuclear Regulatory Commissio.

Washington D.C. 20555 Livermore, CA 94550 Mr. Peggy Buchorn Atomic Safety and Licensing Board Executive Dirdctor U.S. Nuclear Regulatory Comm.

Washington D.C. 20555 Citizens for Equitable Utilities Route 1, Box 1684 Atomic Safety and Licensing Appeal Board Brazoria, Texas 77411 U.S. Nuclear Regulatory Comm.

Washington D.C. 20555 g g Tom Hudson, Esq.

Graves, Dougherty, Hearon & Moody Docketing and Service'Section InterFirst Bank Tower Office of the Secretary Austin, Texas 78701 U.S. Nuclear, Regulatory Comm.

Washington D.C. 20555 Lanny Sinkin 2207 D Nueces Austin, Texas 78705 0~L e:~. BeJL Brian E. Berwick .

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