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| : 2. --ThisE= interrogatories shall be deemed continuing, so l | | : 2. --ThisE= interrogatories shall be deemed continuing, so l |
| as to require additional answers if after answering such | | as to require additional answers if after answering such |
| , interrogatories Applicants obtain information upon the basis of which Applicants know the response though correct when made is aua longer true and the circumstances are such that a failure to amend the response is'in substance a knowing | | , interrogatories Applicants obtain information upon the basis of which Applicants know the response though correct when made is aua longer true and the circumstances are such that a failure to amend the response is'in substance a knowing concealment. |
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| concealment. | |
| 7 | | 7 |
| : 3. If any response is withheld, in whole or in part, for any reason, including but not limited to any' claim cf privilege, confidentiality or trade secret, set forth the basis upon which such response is withheld, and include in such explanation a statement of what is being withheld and the identities of all j persons who have knowledge of the matters being withheld. | | : 3. If any response is withheld, in whole or in part, for any reason, including but not limited to any' claim cf privilege, confidentiality or trade secret, set forth the basis upon which such response is withheld, and include in such explanation a statement of what is being withheld and the identities of all j persons who have knowledge of the matters being withheld. |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20154L2121986-03-0606 March 1986 Response to Citizens Concerned About Nuclear Power,Inc, 860204 Second Request for Production of Documents.Request for Documents Re Drug Use Objectionable Due to Irrelevance to Discovery.W/Certificate of Svc.Related Correspondence ML20137W8731986-02-18018 February 1986 Response & Objections to Citizens Concerned About Nuclear Power Second Set of Interrogatories.Inquiry Into Illegal Drug Use & Programs to Detect Use Is Irrelevant & Unnecessary.Related Correspondence ML20151Z2281986-02-12012 February 1986 Responses to Eighth Sets of Interrogatories Re QA Program & Request for Production of Documents.W/Certificate of Svc. Related Correspondence ML20210B9191986-02-0404 February 1986 Second Set of Interrogatories Re Use,Sale & Detection of Illegal Drugs at Facility.W/Certificate of Svc.Related Correspondence ML20151T3781986-02-0404 February 1986 Second Request for Production of Documents Re Programs Described in Response to Second Set of Interrogatories & Results of Lie Detector Tests Performed Concerning Use of Illegal Drugs.W/Certificate of Svc.Related Correspondence ML20137P6301986-01-29029 January 1986 Eighth Set of Interrogatories & Requests for Production of Documents Re Adequacy of Existing QA Program Described in FSAR Through 851115 Amend 52 & Util Ltrs Through 860110. Certificate of Svc Encl.Related Correspondence ML20077P3091983-09-0707 September 1983 Supplemental Answers to Sixth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20080D2001983-08-26026 August 1983 Answers & Objections to First Set of Interrogatories on Contention 4.Certificate of Svc Encl ML20080D2031983-08-26026 August 1983 Answers & Objections to First Set of Interrogatories on Quadrex.Certificate of Svc Encl ML20024E4001983-08-0808 August 1983 First Set of Interrogatories on Quadrex.Related Correspondence ML20024E4021983-08-0808 August 1983 First Set of Interrogatories on Contention 4.Certificate of Svc Encl.Related Correspondence ML20024A6881983-06-13013 June 1983 Supplemental Answer to Seventh Set of Interrogatories & Requests for Production of Documents Re Site Location Acceptability.W/Certificate of Svc.Related Correspondence ML20072U0211983-04-0404 April 1983 Response to Sixth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20072L5121983-03-28028 March 1983 Seventh Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20071E9591983-03-10010 March 1983 Sixth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20050K0731982-04-0909 April 1982 Objections to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20039G1751982-01-0808 January 1982 Answer to Applicants' Fourth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20039G2381982-01-0808 January 1982 Answers & Objections to Citizens for Equitable Utils & Citizens Concerned About Nuclear Power 811221 Joint Interrogatories & Request for Production of Documents. Certificate of Svc Encl ML20039G0601982-01-0606 January 1982 Answers to Applicant Fifth Set of Interrogatories & Requests for Production of Documents.Intervenor Only Relies on IE Insp Repts 50-498/81-28 & 50-499/81-28 to Support Contention 1.8 (a-d).Certificate of Svc Encl ML20039B4881981-12-21021 December 1981 Fourth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl ML20039B4871981-12-21021 December 1981 Fifth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl ML20039C6911981-12-21021 December 1981 Joint Interrogatories & Request for Production of Documents. Certificate of Svc Encl ML20039G2591981-12-11011 December 1981 Documents Produced in Response to Citizens for Equitable Utils & Citizens Concerned About Nuclear Power 811221 Joint Interrogatories & Request for Production of Documents. Related Correspondence ML20005C0711981-11-0909 November 1981 Suppl to 811106 Interrogatories Filed Per 811030 Memorandum & Order.Questions Deal W/Brown & Root Involvement in Plant Design,Engineering & Const Mgt.Certificate of Svc Encl. Related Correspondence ML20005C0591981-11-0707 November 1981 Interrogatories Filed Per ASLB 811030 Memorandum & Order. Questions Deal W/Brown & Root Involvement in Plant Design Engineering & Const Mgt.Certificate of Svc Encl.Related Correspondence ML20005C0621981-11-0606 November 1981 Joint Interrogatories,Pursuant to ASLB 811030 Order. Certificate of Svc Encl ML20008G1471981-05-0404 May 1981 Interrogatories Directed to NRC Re Partial SER,NUREG-0780, Pursuant to ASLB 810421 Order.Certificate of Svc Encl. Related Correspondence ML20003E2201981-03-23023 March 1981 Supplemental Answers to Applicant Interrogatories Re Individuals Assisting in Answering Interrogatories. Certificate of Svc Encl ML19350C7541981-03-16016 March 1981 Citizens for Equitable Utils Response to Second Set of Interrogatories.Identities of Persons Confiding in Intervenors Will Not Be Divulged.Certificate of Svc Encl. Related Correspondence ML19350C7471981-03-16016 March 1981 Answers to Third Set of Interrogatories from Util.Applicants Already Have Documents Requested.Intervenors Removed Nothing from Swayze Atty Files.Certificate of Svc Encl.Related Correspondence ML19341A3681981-01-16016 January 1981 Third Set of Interrogatories to Citizens for Equitable Utils,Inc Re Intended Witnesses & Testimony in 810504 Licensing Hearing.Certificate of Svc Encl ML19341A3691981-01-16016 January 1981 Fourth Set of Interrogatories to Citizens Concerned About Nuclear Power,Inc Re Intended Witnesses & Testimony in 810504 Licensing Hearing.Certificate of Svc Encl ML19345E0721980-12-0505 December 1980 Third Set of Interrogatories & Requests for Production of Documents to Citizens Concerned About Nuclear Power,Inc. Certificate of Svc Encl ML19341A8741980-12-0505 December 1980 Second Set of Interrogatories & Request to Produce Documents Directed to Citizens for Equitable Utils.Concerns STP Const Records.Certificate of Svc Encl ML19331D3111980-08-25025 August 1980 Interrogatories & Request for Production of Documents Directed to Central Power & Light Re Communication W/Wb Sayles,M Borchelt,Wc Price,T Russell & D Chalker. W/Certificate of Svc & Cover Ltr Urging Response in 14 Days ML19329F7271980-06-13013 June 1980 Answers to NRC Interrogatories & Request for Documents. Identifies DE Swayze as Witness Intended to Be Called Re Nonconformance Repts of Contention 1.DG Bridenbaugh & R Hubbard Will Be Called Re Contention 3.W/Certificate of Svc ML19309F7771980-04-0404 April 1980 Response to Houston Lighting Power Second Set of Interrogatories & Request for Production of Documents. Alleges Void Testing Program Violates 10CFR50,Part B. Certificate of Svc & Supporting Documentation Encl ML19305D0521980-04-0303 April 1980 Second Supplemental Answers to Central Power & Light Co 790223 Interrogatories.Simmons & Woodson Are Expected to Testify Re Interconnections.Certificate of Svc Encl ML19305D0461980-04-0303 April 1980 Third Set of Addl Answers to NRC 790115 Initial Interrogatories.Simmons & Woodson Are Expected to Testify Re Interconnections ML19305C8451980-03-21021 March 1980 Response to DOJ First Set of Interrogatories.Includes Info Re Tx Electric Cooperatives & Wholesale Suppliers. Certificate of Svc Encl ML19309D5291980-03-20020 March 1980 Supplemental Response to First Set of Interrogatories & Requests for Production of Documents.Includes Info Re San Antonio Refusal to Transmit or Receive Interstate Electrical Power.Exhibits Responsive to Interrogatories Encl ML19309D5271980-03-20020 March 1980 Supplemental Response to First Set of Interrogatories & Request for Production of Documents.Includes Info Re Utils Which Purchased coal-fired Economy Energy from City Public Svc Board of San Antonio ML19309D5301980-03-20020 March 1980 Supplemental Response to Brownsville Public Util Board Initial Interrogatories & First Request for Production of Documents.Includes Info Re Joint Action Contemplated by Members of Tx Interconnected Sys.Certificate of Svc Encl ML19309C0101980-03-13013 March 1980 Third Supplemental Response to First Set of Interrogatories & Document Requests.Includes Info Re Gt Taylor Testimony Re Four Relevant Product Markets in Proceedings ML20126C8761980-03-13013 March 1980 Response to Third Set of Interrogatories.Includes Info Re Electric Power & Energy Delivered to Various Utils During Dec 1979.Certificate of Svc Encl ML19309B9951980-03-11011 March 1980 Updated Response to First Set of Interrogatories & Document Requests.Includes Info Re Witnesses,Competitive Utils, Product & Geographic Market & Petitions to Intervene.Prof Qualifications of DA Springs & Certificate of Svc Encl ML19309C7061980-03-11011 March 1980 Supplemental Response to Third Set of Interrogatories & Document Requests.Supplemental Answer to Interrogatory 18 Encl.W/O Encl ML19309D2931980-03-11011 March 1980 Fourth Supplemental Response to First Set of Interrogatories & Document Requests.Includes Info Re Cities & Utils Which Have Explored Power Alternatives Offered by Tx Utils Co ML19309C6991980-03-11011 March 1980 Second Supplemental Response to First Set of Interrogatories & Document Requests.Includes Info Re Projected Loads, Capacity & Reserves as of 800215 ML19309C7111980-03-11011 March 1980 Supplemental Response to First Set of Interrogatories & Document Requests.Includes Info Re Monthly Fuel Cost Adjustments for 1979 1986-03-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ST-HL-AE-4162, Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses1992-07-22022 July 1992 Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses ST-HL-AE-4146, Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants1992-07-0606 July 1992 Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants ST-HL-AE-4145, Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule1992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule ML20101K1131992-06-29029 June 1992 Motion for Leave to Suppl Motion to Modify or Quash Subpoenas & Supplemental Info.* OI Policy Unfair & Violative of Subpoenaed Individuals Statutory Rights & Goes Beyond Investigatory Authority.W/Certificate of Svc ML20101G2041992-06-18018 June 1992 Motion to Modify or Quash Subpoenas.* Requests Mod of Subpoenas Due to Manner in Which Ofc of Investigations Seeks to Enforce Is Unreasonable & Fails to Protect Statutory Rights of Subpoenaed Individuals.W/Certificate of Svc ML20087L3301992-04-0202 April 1992 Affidavit of RW Cink Re Speakout Program ML20087L3491992-04-0202 April 1992 Affidavit of JW Hinson Re ATI Career Training Ctr ML20087L3651992-04-0202 April 1992 Affidavit of Rl Balcom Re Access Authorization Program ML20087L3561992-04-0202 April 1992 Affidavit of Wj Jump Re Tj Saporito 2.206 Petition ML20116F2671992-02-19019 February 1992 Requests NRC to Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility ML20094E9511992-02-10010 February 1992 Requests That NRC Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility & to Adequately Train All Util Employees in Use of Rev 3 to Work Process Program ML20066C5041990-09-24024 September 1990 Comment on Proposed Rule 10CFR26 Re NRC Fitness for Duty Program.Urges NRC Examine Rept Filed by Bay City,Tx Woman Who Was Fired from Clerical Position at Nuclear Power Plant Due to Faulty Drug Test Administered by Util ML20006A0281990-01-0808 January 1990 J Corder Response to NRC Staff Motion to Modify Subpoena & Motion for Protective Order.* Requests Protective Order Until NRC Makes Documents Available to Corder by FOIA or Directly.W/Certificate of Svc ML20005G1431989-12-11011 December 1989 Motion to Modify Subpoena & Motion for Protective Order.* Protective Order Requested on Basis That Subpoena Will Impose Undue Financial Hardship on J Corder ML20005G1451989-12-0505 December 1989 Affidavit of Financial Hardship.* Requests NRC to Provide Funds for Investigation & Correction of Errors at Plant Due to Listed Reasons,Including Corder State of Tx Unemployment Compensation Defunct ST-HL-AE-3164, Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components1989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20205T7001988-11-0101 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Initiation of Fitness for Duty Program at Facility.Need for Program Based on Presumption That Nuclear Power Activities Require That Personnel Be Free from Impairment of Illegal Drugs ML20151M2071988-07-25025 July 1988 Comment Supporting Proposed Rules 10CFR170 & 171 Re Fee Schedules.Principal Objection to Rules Relates to Removal of Current Ceilings on Collection of Fees ML20196A3701988-06-17017 June 1988 Notice of Receipt of Petition for Director'S Decision Under 10CFR2.206 & Issuance of Director'S Decision Denying Petitioners Request DD-88-09, Decision DD-88-09 Denying 880317 Petition by Earth First, Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign & Travis County Democratic Women Committee for Commission to Delay Util Licensing Vote1988-06-17017 June 1988 Decision DD-88-09 Denying 880317 Petition by Earth First, Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign & Travis County Democratic Women Committee for Commission to Delay Util Licensing Vote ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20150D1401988-03-21021 March 1988 Appeal of Director'S Decision on Southern Texas Project.* Requests That Commission Consider Appeal & Stay Licensing Decision Until Sufficient Evidence Acquired to Support Final Decision ML20150D0411988-03-17017 March 1988 Petition Of:Earth First!,Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign, Travis County Democratic Women'S Committee.* Withholding of Issuance of License Requested ML20196H4661988-02-29029 February 1988 Receipt of Petition for Director'S Decision Under 10CFR2.206.* Gap 880126 Petition to Delay Voting on Full Power OL for Facility Until Investigation of All Allegations Completed Being Treated,Per 10CFR2.206 ML20148Q9531988-01-26026 January 1988 Petition of Gap.* Commission Should Delay Vote on Licensing of Facility Until Thorough Investigation of All Allegations Completed & Public Rept Issued.Exhibits Encl ML20237C2751987-12-13013 December 1987 Director'S Decision 87-20 Denying Petitioners 870529 Motion That Record in Facility Licensing Hearings Be Reopened & Fuel Loading Be Suspended Pending Resolution of Issues. Petitioner Failed to Provide Any New Evidence ML20236H3751987-10-29029 October 1987 NRC Staff Consent to Motion to Quash Subpoena Filed by E Stites.* Staff Concedes Possibility of Deficiencies in Svc of Subpoena to Stites & Therefore Does Not Oppose Motion to Quash.Certificate of Svc Encl ML20236E0111987-10-23023 October 1987 Order.* Grants NRC Request for Addl Time to Respond to Motion to Quash Subpoena of E Stites,Per 871008 Order. Response Should Be Filed by 871029.Served on 871023 ML20235T3891987-10-0808 October 1987 Motion to Quash Subpoena & Motion for Protective Order.* Subpoena Issued by Rd Martin on 870922 Should Be Quashed Due to Stites Not Properly Served,Witness Fees & Transportation Costs Not Provided & Issuance in Bad Faith ML20235T4171987-10-0808 October 1987 Memorandum in Support of Motion to Quash or in Alternative in Support of Motion for Protective Order.* Martin 870922 Subpoena of Stites Invalid & Improper.Decision to Subpoena at Late Date Form of Harassment.W/Certificate of Svc ML20195D8561987-09-22022 September 1987 Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant IA-87-745, Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant1987-09-22022 September 1987 Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant 1999-05-04
[Table view] |
Text
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UNITED STATES OF AMc.sicn D00E7D \
NUCLEAR REGULATORY COMMISSION
[p- Uw" f
k' II NOV 10 85
- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1f Ee cf the Secretary 27 b:1&; & Service E A
IN THE MATTER OF ( pn 5
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. HOUSTON LIGHTING AND POWER ( Docket Nos. 498 OL x C.
COMPANY, ET AL. ) 499 OL (South Texas Project, (
Units 1 and 2) )
INTERROGATORIES FROM CITIZENS CONCERNED ABOUT NUCLEAR POWER TO HOUSTON LIGHTING AND POWER, ET AL., APPLICANTS PURSUANT TO MEMORANDUM AND ORDER (Scheduling Prehearing Conference and Evidentiary Hearing on Transition Period Construction Activities) DATED OCTOBER 30, 1981 Preface On October 30, 1981, the Board issued a Memorandum and Order which scheduled an evidentiary hearing to commence on Tuesday, December 8, 1981 in Austin, Texas. See Memorandum and Order (Scheduling Prehearing Conference and Evidentiary Hearing on Transition Period Construction Activities) dated October 30, 1981, at p. 5. The Board scheduled' discovery to commence immediately, Id. Pursuant to the Memorandum and Order of October 30, 1981 and Section 2.740b of the Commission's Rules of Practice.. Citizens Concerned About
, Nuclear Power propounds the following interrogatories to Houston Lighting and Power, et al., Applicants.
-- I. Instructions
_ - -1.-Each interrogatory must be answered separately and fully in writing under oath or affirmation by the person or l persons making them on or before November 18, 1981, Id.
- 2. --ThisE= interrogatories shall be deemed continuing, so l
as to require additional answers if after answering such
, interrogatories Applicants obtain information upon the basis of which Applicants know the response though correct when made is aua longer true and the circumstances are such that a failure to amend the response is'in substance a knowing concealment.
7
- 3. If any response is withheld, in whole or in part, for any reason, including but not limited to any' claim cf privilege, confidentiality or trade secret, set forth the basis upon which such response is withheld, and include in such explanation a statement of what is being withheld and the identities of all j persons who have knowledge of the matters being withheld.
'81TrT8033% -
i L
_2_
II. Interrogatories
- 1. Please provide the dates when Brown and Root, Inc. (B&R) will no longer be performing the following functions at the South Texas Nuclear Project:
- a. Design
- b. Engineering
- c. Construction Management
- d. Construction
- e. Quality Assurance
- f. Quality Control
- 2. What was the basis for the Houston Lighting and Power decision to terminate B&R from each function set forth as
- a. through f. in Interrogatory l?
- 3. Regarding functions a. through f. in Interrogatory 1, please specify the following:
- a. the functions Bechtel Corporation has agreed to perform
- b. the form of the Bechtel Corporation commitment to perform each function, e.g. commitment letter signed, contract signed, etc.
- c. the terms and condition under which Bechtel Corporation has agreed to perform each function.
- 4. Please give numerical totals in each area set out as a.
through f. in Interrogatory L,for the number of personnel given notice of termination of employment since the date Houston Lighting and Power notified B&R of HL&P's intent to terminc.te B&R's responsibilities for design, engineering, and construction management:
- a. by HL&P
- b. by B&R
- 5. Please give numerical totals in each area set out as a.
through f. in Interrogatory 1 for the number of personnel giving notice of their intent to terminate employment since the date Houston Lighting and Power notified B&R of HL&P's intent to terminate B&R's responsibilities for design, engineerino,.
and construction management:
- a. with HL&P
- b. with B&R
- 6. Is B&R still aut.thorized to hire additional personnel to work on the South Texas Nuclear Project?.
- 7. If the answer to Interrogatory 6 is "yes" in what areas set out as a. through f. in Interrogatory 1 is such additional hiring authorized?
- 8. Has B&R placed a hiring freeze on new employees for the South Texas Nuclear Project?
I
- 9. If the answer to Inte rrogatory 8 is "yes," please specify:
- a. what areas set out as c. through f. in Interrogatory 1 such hiring freeze is in place
- b. when the hiring freeze was put in place for each area.
- 10. What steps or actions, if any, have HL&P, B&R, and/or Bechtel Corporation taken to insure the morale during the transition period of QA and QC personnel now employed by B&R?
- 11. What steps or actions, if any, have HL&P, B&R, and/or Bechtel Corporation taken to insure the morale during the transition period of B&R personnel in areas set out as a.
through d. in Interrogatory 1?
- 12. When was the Quadrex report received by HL&P?
- 13. When was the Quadrex report received by B&R?
- 14. Which findings in the Quadrex report related to safety and/or licenseability might affect transition period construction as specified in the October 16 letter?
- 15. For each finding listed in response to Interrogatory 14, specify the steps or actions taken by HL&P to address and resolve the deficiency.
- 16. If not previously answered, please specify what steps or actions have been taken by HL&P to identify non-safety-related items which should have been classified as safety-related.
_~__
17 Please list all items reclassified from non-safety-related s Efetyrrelated since HL&P received the Quadrex report.
m Mease list, with an identification for each item as sr ,
elated or non-safety-related at the time of performance, ai construct 1bn items performed:
- a. since HL&P received the Quadrex report
- b. since the date HL&P notified B&R of HL&P's intent to rminate B&R's responsibilities for design, engineering, and construction management
- 19. Please list:
/ a. all items of construction approved by the Nuclear Regulatory Commission for performance after the NRC received the Quadrex report.
- b. the date each item was performed or identification of performance as still pending.
- 20. Does HL&P propose to have Bechte(, Corporation address and resolie the Quadrex finding thd[B&R filed to adequately distinguish between safety-related and non-safety-related items of construction?
- 21. If the answer to Interrogatory 20 is "yes," how lo1g does Bechtel estimate it will need to resolved this finding'
- 22. Does HL&P propose to have Bechtel Corporation address and resolve the findings listed in response to Interrogatory 14?
- 23. If the answer to Interrogatory 22 is "yes," please give Bechtel's estimate for the length of time to resolve each finding.
- 24. Please give:
- a. specific identification of the two findings in the Quadrex report reported by HL&P to the NRC pursuant to 10 C.F.R Section 50.55 (e)
- b. the identities of persons who participated in the decision making process which led to reporting these two items
- c. the identities of the persons who participated in the decision making process which led to the release of the Quadrex report to the Board, NRC staff, and Intervenor representatives.
- 25. Please list any steps or actions taken by HL&P to insure the quality of safety-related., construction to be performed
~
during the transition period can later be verified.
- 26. Please identify all measures taken to protect partially completed work at the South Texas Nuc.'. car Project during previously issued stop work orders.
- 27. What items of partially completed, safety-related work (as this term was previously used by B&R) are subject to deterioration if all safety-related work is stopped? Describe fully the item and the potential for deterioration.
- 28. What are the relative safety implications of continuation of only such transition work outlined in the October 16 letter as have already been commenced as of that date?
- 29. Please list any studies, reports, evaluations, or similar documents concerning possible deficiencies in either the contruction or QA/QC programs at the South Texas Nuclear Project prepared by the Bechtel Corporation.
- 30. Please list all studies, reports, evaluations, or similar documents concerning possible deficiencies in either the construction or QA/QC programs at the South Texas Nuclear Project prepared by an entity other than Bechtel Corporation.
s
/
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-Q- 1 NOV 101981 US 32 *,'i '2 t
STATES OF AMERICACOMMISSION BOAR ,q.
1=%~ i, scr;in UNITEDREGULATORYLICENSING g NUCLEAR AND Yj . ;
SAFETY - l i hu
) Nos. 498 OL 499 OL of )
Doc ket In the Matter d Power (
)
Houston Lighting A1 an (
Company, Et )
Texas Project,
- 2) OF SER" ICE IES FROM (SouthUnits 1 and CERTIFICATE of INTERROGATORHOUSTON LIGHTING.
AND t copiesPOWER TO MEMORANDUM TO hereby certify thaNUCLEARPURSUANT and Evidentiary )
ABOUT I
CONCERNED APPLICANTS Conference ction Activitieslowing tes CITIZENSPOWERg, ET AND AL Prehearingion. , erved sPeriod on Constru the in the United Sta fol ha ve been deposit cial DeliveryNovember, 1981 ORDER (SchedulinHearing on Transitand e DATED OCTOBER 30, 1981 7th wan, Esq. Plaza first class, postagby individuals Mail, asterisk, Finis Co on this 7002 One Shell 3000 as indicated ffer, Esq. Houston, Texas 7 Esq. l Charles Chairman Bechhoe
, ASLB y Commission Brian Berwick, e Attorn y GeneraCapitolSta Nuclear Regulator 20555 Assistant P. O. Box 12548, 11 Washington, D.C. III Austin, TX. 787 Esq.
b Legal Dr . J ames C . Lam ,ven Road CarolinaJay 27514 M. Gutierrez,of the Executive 313 WoodhaHill, North Office Chapel Director
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Mr. Ernest Washington , D.C. ing Lawren ce Livermore 123 LaboCalifornia ty and Licens University of f rnia 94550 Atomic Safe P. O. Box 808,III,L-Livermore, Esq. Cali o Board 20555 William S. Jordan, U.S.N.R.C. Washington, D and Weiss HarmonI Steet, N .W . Atomic Safety Boardan 1725 20006 Appeal 20555 Suite 506 Washington, D.C; U.S.N.R.C. Washington, Buchorn vie Sec tionD.C Mrs. Peggyute 1, 422Box 1684 Docketing and Serof the Se Ro Bazoria, Tx. 77
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