ML20212N598

Applicants Interrogatories to Intervenor (Set Number 1987-8).* Interrogatories Concern Application for Ol. Certificate of Svc Encl.Related Correspondence

ML20212N598
Person / Time
Site:	Comanche Peak
Issue date:	03/05/1987
From:	Selleck K ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
CON-#187-2752 OL, NUDOCS 8703130090
Download: ML20212N598 (58)

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Filed: h 5, 1987 UNITED STATES OF AMERICA -

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NUCLEAR REGULATORY COMMISSION-before the (F h[rf

. u. A -

ATOMIC SAFETY AND LICENSING BOARD

)

. In the Matter of.

) Docket Nos. 50-445-OL

_. ) 50-446-OL 3 TEXAS UTILITIES GENERATING )

COMPANY et al. )

. . ) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

).

APPLICANTS' INTERROGATORIES TO INTERVENOR (Set No.-1997-8)

Pursuant to 10 C.F.R. 5 2.740 ff the Applicants hereby propound the following interrogatories to Intervenor CASE.

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• Definitions As used in these Interrogatories, the following terms

'have the following meanings:

" Litigate" with regard to a topic or contention means to L offer direct testimony relating to, to cross-examine on, to 4

offer proposed findings or rulings regarding, or to urge the j denial (or allowance subject to conditions) of the pending L

application on the basis of, the topic or contention in question.

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" Identify" with respect to an expert witness means to

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state:

(a) The name, mailing address, age and present professional or employment affiliation of the person; (b) The profession or occupation and field of claimed expertise of the person; (c) The history of formal education or training of the f

person, . including, but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to, (i) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; (e) The history of membership of the person in any professional or trade association in the area in '

the claimed expertise, including, but not limited to, (i) the name of each professional or trade association, (ii) the dates of membership, and

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(iii) a-description of each office held in-each

- . association; .

(f) A list of publications of_any kind by the person in the area of-claimed expertise, including,;but not limited to, (i) the title and subject matter, (ii) the name and address of the pu'blisher, and (iii) the date of publication; (g) A list of any and-all licenses in the area ~of claimed expertise, including,_but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining.

each license, and (iv) the manner by which these requirements.were met; (h) -The amount of time the person has worked in the field of claimed expertise, stating periods where

' work war other than on a full-time basis; (i) The name and address of every person, or every l corporation or other institution, that has employed the person within the last ten years of employment; L (j) All periods of claimed self-employment, including a l-description of all duties and responsibilities thereof; (k) All previous experience in the field of claimed l

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expertise which' involved problems, analyses or studiesisimilar to those concerning which the person is expected to' testify in this proceeding; (1). All other litigation in which the-person has been consulted, specifying those matters in which the person has testified, including the name of the

' case or matter and the court or other forum inn 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 cections of.the Results Reports cited herein should be read in the context that they appear within the Results i

Reports so that these interrogatories can be answered adequately.

! I-1. Does the Intervenor intend to litigate the l validity of the conclusions expressed in the following l'

statement? (If the answer to this Interrogatory is an unqualified negative, you may proceed to II-1). -

'None of the four documentation deviations (described in l the Bosults Report for Action Plan I.a.1] was determined to be aafety-significant, since the absence of conclusive documented evidence of heat-shrinkable insulation sleeve installation and inspection would not by itself result in the loss of capability of the sleeve i

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-to perform its intended safety. function. '(Results

' Report;EISAPiI.a.1, page 20).

- I-2. _Please state;each and.every respect in which CASE -

disagrees with the above' statement..- '

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' (a)~.On what'. 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) Does1the Intervenor intend to offer the testimony ofiany-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;.

i' (ii) state the substance of the facts to which each expert-witness is1 expected to testify; l (iii) . state the substance of the opinion or opinions to which each expert witness is expected to testify; ,

(iv) provide a summary of the grounds for each opinion to which each expert witness is expected to testify; 5-f a

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4 (d) Does-the Intervenoridisagree 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 in) 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-3. Prior to answering this set of Interrogatories,

'has the Intervenor reviewed the Working File for the Results Report in question?

I-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?

II-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If the answer to this Interrogatory is an .

. unqualified negative, you may proceed to III-1.)

Neither of the two hardware deficiences was determined to be safety-significant. (This was because] in each case, the heat-shrinkable insulation sleeves were not located in harsh environmental areas. Though the sleeves were not installed in full accordance with the 2 i

1 manufacturer's11nstructions, the installations were adequate to provide electrical installation in a mild environment. (Results Report, ISAP I.a.1,.page 20).

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, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d)- Does the Intervenor disagree with the above statement due~to the methodology through which the statement's conclusions were reached? If so, state the precise manner in which the methodology was flawed.

(e) Does the Intervenor disagree with the above

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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.

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j. f III-1. Does;the Intervenor intend to litigate the x

validity. of the conclusions expressed in' the following statement?L .(If?your answer is.an unqualified negative you may proceed to:IV-1.)

[C]orrect installation of heat-shrinkable. insulation sleeves primarily requires patience and careful attention to detail. There are no skills necessary to.

properly install these' sleeves beyond.those of any qualified electrician. Therefore,-inadequate qualification of craft personnel was determined not to be a root cause. '(Results Report, ISAP I.a.1, pageL22).

.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 e disagreement?

(b) Identify the documents Intervenor will rely upon to

, sustain its position of disagreement with the statement, or any portion thereof.

1 1-(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

answer all Interrogatories I-2(c)(i) - I-2(c)(iv)

I with regard to their proposed testimony. .

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(d) Does the Intervenor' disagree with the above s

statement due to the methodology through which the statement's conclusions were reached? If so, state l

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the, precise manner in which the methodology was iflawed.

L (e) LDoes 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 fl awed.

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).

[T]here is reasonable assurance that heat-shrinkable insulation sleeves have all been installed where required. (Results Report, ISAP'I.a.1, page 26).

, 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 of any expert witness with respect to the validity of the conclusion reached in the above statement?

If so, please answer all Interrogatories I-2(c)(1)

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- I-2(c)(iv) with' regard to.their proposed-testimony..

(d), Does the Intervenor disagree'with the above statement due toLthe' 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 thefimplementation of the action ,

f planothrough.which-the statement's conclusions were reached? If so, state the precise manner'in which

'the implementation was flawed.

4 V-1. Does the Intervenor intend to litigate the t validity of the conclusions expressed in the following statement? (If.your answer is an unqualified negative, you

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may proceed to VI-1).

[T]he objective of Part 2 of ... ISAP [I.a.1) has only partially been met. Implementation of the corrective

, action specified in Section 5.9.1 [of I.a.1] will complete the' remainder of that objective. (Results Report, ISAP I.a.1, page 26).

l V-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

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. sustain its position of disagreement, or any portion thereof.

(c) Does'the Intervenor. intend to offer the testimony of any expert witness with respect to the above statement? If so, please answer all Interrogatories ~I-2(c)(1) -

I-2(c)(iv) with respect-to their proposed testimony.

(d) Does the Intervenor disagree with the above statement.due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.

f (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.

VI-1. Does the Intervenor intend to litigate the t

validity of the conclusions expressed in the following statement? (If your answer is an unqualified negative, you may proceed to VII-1).

[T]here is reasonable assurance that undocumented plug '

welds not reinspected under this action plan will not compromise the structual integrity of the components.

(Results Report, ISAP V.d, page 35).

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!- VI-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

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n (a) -On what specific facts.does the.Intervenor' base-its

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disagreement?.

(b).1 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 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 i reached? If so, state the precise manner in which the implementation was flawed.

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l VI-3. Prior to answering this set of Interrogatories, i has the Intervenor reviewed the Working File for the Results .

Report in question?

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. VI-4. Has the Intervenor propounded any Interrogatories i

regarding the Results Report in question in order to obtain l-  :

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any information it believes to be necessary so as to make  !

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'~its review of the' Working File complete?

VII-1. Does the Intervenor intend to litigate the validity of the~ conclusions expressed in the statement a

below?; (If your answer to this Interrogatory is an

- g unqualified negative, you may proceed to VIII-1.)

The current procedures and practices for the repair of mislocated holes, including their inspection and documentation are adequate to preclude the recurrence of undocumented plug welds. (Results Report, ISAP V.d, page 36).

VII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor 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.

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(d) Does the Intervenor disagree with the above statement due to the methodology through which its i

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. ; .e conclusions were reached?- If so, state the precise manner in which the methodology flawed.

(e). Does the Intervenor disagree with the above-

. statement due to the implementation of the action

. plan'through which the statement's' conclusions were reached? If so, state the precise manner in which the implementation was flawed.

VIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to IX-1.)

[T]he-practice of using QC acceptance stickers or inspector initials marked on the support as the only record of inspections for-some plug welds in cable tray and cable tray supports is not safety-significant.

(Results Report, ISAP V.d, page 33).

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 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, 3 -

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K . please; answer.all Interrogatories I-2(c)(i) -

I-2(c)(iv).with regardi 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, please state the precise manner in which the.

methodology was flawed.

(e) DoesEthe 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.) l

[T]he lack of permanent plug weld' inspection records appears to be. limited'to a small portion of the population and did not adversely reflect on the' quality of the plug welds. (Results Report, ISAP V.d, page 32).

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?

s (b) Identify the documents Intervenor will rely upon to 15 -

sustain.its position of disagreement, or any-portion thereof.

(c) Does,the Intervenor intend to offer the testimony of any expert witness with~ respect to'the conclusion reached in the above statement? If so, please answer'all Interrogatories I-2(c)(1) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology 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.

X-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XI-1.)

[F]or the geometry of a typical plug weld, using a '

suitable welding procedure, sufficient slag will not be entrapped to reduce the strength of the welded section to less than the minimum required of the base metal.

Visual inspection and acceptance of plug welds in the ground condition also provides evidence that the weld will meet the applicable strength requirements.

(Results Report, ISAP V.d, page 29).

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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)(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 1

reached? If so, state the precise manner in which the implementation was flawed. -

XI-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following

statement?1 .(If your answer to this Interrogatory is an

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-unqualified negative, you may proceed to XII-1.)

[T]here is a reasonable assurance that currently there are no adverse hardware conditions in1the plant resulting from past problems with the operation of the

[ Document Control Center]. (Results Report, ISAP VII.a.3, page 11).

XI-2. Please state each and every respect which the Intervenor disagrees with the above statement.

(a) On what specific facts does the-Intervenor base'its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend to offer the testimony.

, of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.

(e) Does the Intervenor disagree with the above 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 i'mplementation was flawed.

XI-3. Prior to answering this set of Interrogatories, has-the Intervenor reviewed _the Working File for the Results ,

Report in question?

XI-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?

XII-1. .Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XIII-1.)

[Alny additional root cause analysis would not likely identify inadequacies in the implementation of the document control program through the (Document Control Center]. (Results Report, ISAP VII.a.3,'page 9).

XII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

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(c) lDoes:the Intervenor intend to offer the testimonyL of any. expert witness withfrespect 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) iDoes 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.

XIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XIV-1.)

(T]he controls for, and operation of, the DCC pertaining to the distribution of drawings and drawing changes is satisfactory. (Results Report, ISAP VII.a.3, page 9).

XIII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

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-(a) -On what. specific facts does the Intervenor base its d'isagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with-the above statement due to the methodology through which its conclusions were reached? If so, state the manner in which such methodology is flawed.

(e) .Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the manner in which the implementation was flawed.

i 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.)

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[A]ll seismic gaps have been identified and have.been or. l

, will be inspected, with two exceptions identified.to date. For these two cases,' acceptable justifications were developed that demonstrate seismic separation is maintained. -(Results Report,' ISAP II.c, page:38).

~XIV-2. Please state each:and every respect in which'the  ;

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Intervenor disagrees with the above statement.

(a) On what specific facts does-the-Intervenor base its i 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 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 a

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reached?' If so, state the manner in which the-implementation is flawed.

XIV-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File'for the Results Report in question?

XIV-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?

XV-1. Does the Intervenor intend to litigate the

• validity.of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XVI-1.)

(T]he procedures used and their implementation have been

effective in assuring that the design' gap width is achieved, that'the gaps are. free of debris'and that they are protected from future debris instrusion. (Results Report, ISAP II.c, page 39).

XV-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

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(c):. DoesLthe IntervenorLintend to offer the-testimony of.any' expert' witness.with respect ~to the

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conclusion = reached in the_above statement? If so,.

please. answer all: Interrogatories I-2(c)(i) ,.

I-2(c)(iv)~dith regard to their proposeditestimony.

(d) Does^the Intervenor.. disagree-with the above statement due.to the methodology through which its.

conclusions were reached?' If so, state the precise

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manner in which the methodology was flawed.

(e) Does the Intervenor' disagree with the above statement due to the-actual implementation of the

' action plan through which the statement's-conclusions were reached? If so, state the precise manner in which the implementation was flawed.

XVI-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 XVII-2.)

[Clalculations to establish the design basis building

., displacements and to confirm that the (elastic foam) materials designed to be present in the seismic gaps (e.g., environmental and fire seals) do not invalidate the assumptions or dynamic models used to analyze the -

seismic response of the building. ...[T]hese calculations ... correctly reflect the FSAR commitment for seismic separation, and demonstrate that the presence of these materials do not have a significant effect on the seismic response of the buildings.

(Results Report, ISAP II.c, page 39).

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XVI-2; .Please' state each-and every-respect in which the Intervenor disagrees with the above~ statement.

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(a). On whatLspecificffacts does the Intervenor base its disagreement?

(b) . Identify the d6cuments Intervenor will rely upon to sustain its position of disagreement, or any portion.thereof.

(c)

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Does the Intervenor intend to offer-the testimony-of any expert witness with respect to the conclusion reached'in the above statement? If so,-

please answer.all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) -Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which 4

the implementation was flawed. '

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XVII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following

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,i

- statement? \(If~your answer'is an unqualified' negative, you ,

1. 4 y may proceed to 1%VIII-1.) *

.g1 .

.x ,

(T]he question of potential damage due to the . .

building-to-bdilding. contact duriny [Structual Integrity Test] ha(s} been satisfactorily rssolved. (Results Report, ISAP II.c, page 39). ,

XVII-2. Please' state each And every respect in which the Intervenor disagrees with the above statement.

, f ,'

(a)' On what specific-facts days the Intervenor base its

. disagreement? -

(b). . Identify the documents l'nterverar wi).1 rely upon to x sustain 1,ts position of disagreement,.or any portion thereof.

. ., u (c) - Doec the!Intervenor intend to offer the testimony of a$y-4xpert witness with respect to the conclusion reached in the above state,mant? 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 i

o statement due to the. methodology through which its co,nclusions s.cre reached? If yo, state the reasons why the methodology was flawed. -

(e) Does the Intervenor disagree with t E ebcVe statement due to the implementation of the action plan through which the statement's conclusions were, 26 - -

! g

.- -- _, , , - - - - . - - , ., ..__ _ -.-_. --. - - ~ . __ -m . _ , _ - - - - - - - - - _ - _ _ ~

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p.-

reached? If so, state'the reasons why the.

-inplementation was flawed..

XVIII-1., Does the Intervenor intend to litigate.the validity of the: conclusions expressed in the following. ,

statement? -(If your answer to this-Interrogatory is an unqualified negative, you may proceed to-XIX-1.)

h.

(y<,

[A]ction plan [II.c] has fully addressed the generic implications relative to seismic separation gaps. . . .

[S]imilar deficiencies, if they existed in other areas, would be detected by the investigations being conducted under ISAPs II.a, II.d, VI.a and the DAP and Quality of Construction programs. (Results Report, ISAP II.c, page 40).

XVIII-2. Please state each and every respect in which the f Intervenor disagrees with the above statement.

( '

T (a) On'what specific facts does the Intervenor base its y dis'a greement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any po'etion 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' , I 2(c)(iv) with regard to their proposed testimony.

is g (d) Does the Intervenor disagree with the above L, ,

L'

~

statement due to the methodology through which its 4

[ .:

6: .

conclusions were reached? If so, state the reasons why the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state why the implementation was flawed.

XIX-1. Does the Intervenor intend to litigate the L

validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XX-1.)

[I]f implemented as planned, the [ corrective actions outlined in $5.7] ... will correct the identified deviations and adequately address the root causes

, determined by the Electrical Review Team. [These '

actions also] adequately address the generic implication associated with all multi-train panels. (Result Report, ISAP I.b.4, page 20).

i XIX-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts'does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any ,

portion thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the'above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of-the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.

XIX-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?

XIX-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?

XX-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXI-1.)

The program described in Section 5.7 will ensure that separation inside multi-train panels in Units 1, 2 and

4 common areas will be established and maintained.

(Results Report, ISAP I.b.4, page 23).

XX-2. Please state each and every respect in which the

'Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any 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.)

[The] corrective action program as discussed in Section 5.7, ... will ensure that all concerns involving separation in electrical panels are resolved. (Results Reports, ISAP I.b.4, page 23).

i XXI-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend te offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons '

why the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of the action l

l l  :

l

( -

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.)

. SERVICAIR flex [can) carry currents representative of the maximum fault currents expected at the control boards and vertical ventilation panel without imposing damage to Tefzel cables in an adjacent touching Flex ~

even if the fault current were to flow through both of the touching Flex conduits. (Results Report, ISAP I.b.1, page 17).

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.

(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.

XXII-3. Prior to answering this set'of Interrogatories,.

has_the Intervenor reviewed the Working File for the Results Report in question?

XXII-4. Has the Intervenor propounded any Interrogatories regarding the Results Report in question inLorder to obtain any information it believes to be necessary so as to make its review of the Working File complete?

XXIII-1. Does the Intervenor intend to litigate the .

validity of the conclusions expressed in the following

'- statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIV-1.)

SERVICAIR flex meets the IEEE 384-1974 definition of a barrier when both cables are Tefzel-insulated. (Results Report, ISAP I.b.1, page 21). ,

XXIII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

a 1 ^.. o.

I I

I (a). On what specific facts does the Intervenor base its disagreement? l l

.i (b); Identify the documents Intervenor will tuly 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.

(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 the precise manner in which the implementation was flawed.

XXIV-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following l

C' o statement?' (If your answer to this Interrogatory is an unqualified negative, you may proceed'to XXV-1.)

[T]he TUGCO program outlined in Section 5.10 ... will ensure that the use of SERVICAIR flex meets the final separation criteria developed as a result of this action ,

plan. (Results Report, ISAP I.b.1, page 33). I XXIV-2. Please state each and every respect in which the 1

Intervenor disagrees-with the above statement. 1 (a) On what specific facts does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were

.e , 1 l

l reached?. If so,. state the reasons why the q implementation was flawed.

1 XXV-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 XXVI-1.)

SERVICAIR flex is an acceptable barrier for the majority of the circuits in the control room. control boards and vertical ventilation yanels. For the remaining circuits, a one-inch separation'is [ adequate). (Results Report, ISAP I.b.1, page 34).

XXV-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 e ,

conclusions were reached? If so, state the reasons

_w hy 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.

XXVI-1. Does 'he-Intervenor t intend to litigate the l- ' validity of the concit.sions expressed in the following.

statement? (If your atswer to this Interrogatory is an unqualified negative, you may proceed to XXVII-1.)

These actions [ outlined in Section 6.O}, in conjunction with-the completion of ongoing activities, will ensure thattall concerns regarding separation lof redundant-cables, each enclosed in a SERVICAIR flex, are resolved.

(Results Report, ISAP I.b.1, page 34).

p XXVI-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) Daes the Intervenor disagree with.the above statement-due to the methodology through which its' conclusions were reached? If so, state the reasons why the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan.through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.

XXVII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXVIII-1.)'

These actions [ outlined in 6.O], in conjunction with the completion of ongoing' activities, will ensure that all concerns regarding separation of redundant cables, one of which is enclosed in SERVICAIR flex, are resolved.

(Results Report, ISAP I.b.2, page 35).

XXVII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its .

i disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons _

why the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.

XXVII-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?

XXVII-4. Has the Intervenor propounded any Interrogatories regarding the z.asults 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?

XXVIII-1. Does the Intervenor intend to litigate the 1

validity of the conclusions expressed'in the following statement? -(If your answer to this Interrogatory is an.

I _ unqualified negative, you may proceed to XXIX-1.).

( The aforementioned inspections [ outlined _in ISAP I.b.2],

in conjunction with the completion of ongoing activities, will ensure that all deviations to the final separation criteria for exposed. cables to SERVICAIR flex have;been identified and corrected. (Results Report, L 'ISAP I.b.2, page 35)'.

XXVIII-2. Please state each and every respect in which the Intervenor_ disagrees with the above statement.

(a) -On_what specific facts does the Intervenor base its

-disagreement?-

(b) Identify the documents Intervenor will-rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d)- Does the Intervenor disagree with the above statement due to the methodology through which its '

conclusions were reached? If so, state the reasons why the methodology was flawed.

(e) Does the Intervenor' disagree with the above

l 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.

XXIX-1. Does the Interver:or intend to litigate the validity of the ccac.1"rzons expressed in the following-

+

statement? (If your a...wer to this Interrogatory is an unqualified negative, you may proceed to XXX-1. )

~

'SERVICAIR flex in combinati'on with~a one-inch-gap from an' exposed cable is an acceptable barrier for_the majority of the circuits in the control room control boards and vertical ventilation panels.. For the remaining circuits, a six-inch separation is [ adequate, and] is the same separation required for two exposed-cables. (Results Report, ISAP I.b.2, page 35).

XXIX-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its disagreement?

(b)' Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the ,

conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

l l

l I

I L

-(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 implementaticn was flawed.

XXX-1. Does the ~Intertrenor -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 XXXI-1).

The corrective action described in the Results Report for Action Plan I.b.1 will ensure that separation inside multi-train panels will be established and maintained.

(Results Report, ISAP I.b.2, page 35)..

XXX-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.

. .: u (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) - j l

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the'Intervenor disagree with the above statement due to the methodology through which-its conclusions were reached? If so, state the reasons why the methodology was flawed.

(e) Does the Intervenor, disagree with the above statement due to the implementation of the action plan 1through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.

XXXI-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 XXXII-1).

l SERVICAIR flex meets the IEEE 384-1974 definition of a l barrier when both cables are Tefzel-insulated. (Results Report, ISAP I.b.2, page 22).

XXXI-2. Please state each and'every respect in which the Intervenor disagrees with the above statement.

l I .. .- -. .. -- .. -

.. s

~

(a) On what specific facts does the Intervenor base its disagreen.ent?

(b) Identify-the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.

(c)- Does the Intervenor intend to offer the testimony of any expert witness with respect to the validity of the conclusion reached in the above statement?

If so, please answer all Interrogatories I-2(c)(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.

l- (e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the manner in which the implementation was flawed. ,

XXXII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following g, ;, . ,

statement?' (Iftyour answer is an unqualified negative, you may proceed to XXXIII-1).

.[S]tation procedures provide evaluation of deferred

.preoperational. testing and includes, among,other things, consideration of the requirements of the: Technical Specifications. (Results Report, ISAP III.a.3, page 4).

-XXXII-2. Please state each and every respect in which-l

the Intervenor disagrees with the above-statement.

l-(a) On.what specific facts does the Intervenor baseLits disagreement?

(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any

-portion thereof.

(c) Does the Intervenor intend to offer the' testimony of any expert witness with respect to the above statement? If so, please answer all Interrogatories I-2(c)(1) - I-2(c)(iv) with respect to their proposed testimony.

(d) Does the Intervenor disagree with the.above statement due to the methodology _through.which its conclusions were reached? If so, state the precise manner in which the methodology was flawed. ,

(e) 'Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were

.c. . . .

it reached? If so,. state the precise' manner in'which' the implementation was flawed.

~

XXXII-3. Prior,to answering this set of Interrogatories,.has the Intervenor reviewed the Working File'for the Results Report'in' question? '

XXXII-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?

XXXIII-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 XXXIV-1).

[N]o generic condition exists which indicates that there are inadequate controls.with regard to review of-deferred preoperational testing for adherence to the requirements ~of Technical Specifications. (Results Report, I3AP III.a.3, page 4).

XXXIII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

1 (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. ,

~

6

.

-(c). Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.

(e) Does the Intervenor disagree with the above statement due to the implementation of~the action plan through which the statement's conclusions were reached? If so, state the manner in which the implementation was flawed.

XXXIV-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 XXXV-1).

The B&R Construction procedures define measures for housekeeping and cleanliness control which satisfy the program basis requirements shown in Appendix 2 (to this j Results Report]. (Results Report, ISAP VII.a.7, page 8). '

L XXXIV-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

i

s. r l

I (a) On what specific facts does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to i s sustain its position of disagreement, or any

)

portion.thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above. statement? If so, please answer all Interrogatories I-2(c)(1) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology' flawed.

(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.

XXXIV-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?

XXXIV-4. Has the Intervenor propounded any

, . .= .. . _ . - - . . _

E 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?

XXXV-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 XXXVI-1.)

The B&R and'TUGCO [ construction and Startup/ Turnover]

quality-procedures listed on Appendix 3 [to this Results Report] adequately address all of the elements of an effective surveillance program with three minor =

exceptions [as discussed on pages 9-10]. (Results Report, ISAP VII.~a.7, page 8).

XXXV-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

!~

% i h statment due to the methodology through which its 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 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.

XXXVI-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 XXXVII-1.)

[The] eight (8) swipe tests plus water chemistry samples

[are]' adequate to demonstrate acceptable cleanliness of the Reactor Vessel. (Result Report, ISAP VII.a.7, page 18).

XXXVI-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 l

sustain its position of disagreement, or any ,

portion thereof.

(c) Does the Intervenor intend to offer the testimony 1

of any expert witness with respect to the l-l

d - _ s; - ,

- 1 conclusion reached:in the.above statement? 'If so,-

~

please answer all Interrogatories I-2(c)(i) -

'I-2(c)'(iv) with. regard ito their proposed testimony.

~

-(d) Does-the Intervenor disagree with-_the above statement due to the:meth'odology 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 statementfdue 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.

XXXVII-1. Does the Intervenor intend-to litigate the validity of the conslusions expressed in the following Estatement? (If your answer to this Interrogatory is an!

I unqualified negative, you may proceed to XXXVIII-1).

O Implementation of current TUGCO and B&R procedural requirements is ... adequate and [is] effective in

, identifying and obtaining resolution of unsatisfactory

}

conditions. (Results Report, ISAP VII.a.7, page 20).

?

XXXVII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.

1 (a) On what specific facts does the Intervenor base its

' disagreement?

(b) Identify the documents Intervenor will rely upon to i

o

! t

. .- .- - . . - . _ _ _ . _ _ , , . . . , , , , . , _ _ . - , - _ . ~ , . . . . . , . . , , , , _ . . . . , - _ . - - . , , - , . .,-.,_m_,-__

I [$L '.: -

t sustain'its position of disagreement, or any portion thereof.

(c) Does-the Intervenor intend'to offer the testimony of any expert witness with respect to the conclusion reached in :the above statement? If so, please answer all Interrogatories I-2(c)(i) -

I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above statement due-to the methodology through which'its conclusions were reached? If so, state the precise manner in which the methodology was flawed.

(e) Does the~Intervenor' disagree with-the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.

XXXVIII-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 XXXIX-1.)

The current CPSES program for housekeeping activities, including surveillance, complies with 10 CFR 50, Appendix B and the associated commitments of the CPSES FSAR-shown in Appendix 2. (Results Report, ISAP VII.a.7, page 22).

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XXXVIII-2. Please state each and every respect in which the Intervenor disagrees with.the above statement.

(a) On what specific facte does the Intervenor base its disagreement?

(b) Identify the documents Intervenor will rely upon to

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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)(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 i statement due to the implementation of the action plan through which the statement's conclusions were

! reached? If so, state the precise manner in which -

i the implementation was flawed.

l-XXXIX-1. Does the Intervenor intend to litigate the l

i validity of the conclusions reached in the following l

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statement? (If your answer to this Inherrogatory is an n

unqualified, negative, you may proceed to XXXX-1.)

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[H]ousekeeping practices and surveillance activities were not a contributing factor to the accumulation of n.'

debr'is in the seismic gaps and critical spacos which

[were] found through Action PlanLII.c and VI..a'.

(Results Report, ISAP VII.a.7, page 23).

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XXXIX-2. Please state each and every respect'in'which a

the Intervenor disagrees with the above statement.

(a) On what specific facts does the Intervenor base its disagreement?'

.. ,x (b) Identify the documents Intervenor will rely upo'n to - '

sustain its position of~ disagreement, or any

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port ion; thereof.

(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the -'

concittsion reached in the above statement?', If so, please answer all Interrogatories I-2(c)(1) g I-2(c)(iv) with regard to their proposed testimony.

(d) Does the Intervenor disagree with the above '

l .

l statement due to the methodology through which its '

conclusions were reached? If so, state the precise ,

manner in which the meth8dology was flawed.

l (e) Does the Intervenor disagree with the above l

statement dui to the implement 5. tion of the action e

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.planathrough which the statement's conclusions 1were reached?. . If so, state the precise manner-in which.

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the' implementation was flawed.

XXXX-1. Does the Intervenor intend.to litigate the validityofphe;conclusionsreachedinthefollowing statement?

,  ;( The TUGCO' action,. currently in process [as' described in f)j' . the Results Report],- t;a review and revise ' procedures -

! affecting system cleualiness activities will be adequate to preclude ~ recurrence.of. swipe test problems. (Results Report, ISAP VII.a.7, page.26).

XXXX-2. Please state each and every-respect in which the Intervenor disagrees with the above statement.

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'l (a) On what specific. facts does the Intervenor base.its i disagreement?-

(b) Identify the documents Intervenor willErely upon to sustain its position of disagreement, or any

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portion-thereof.

, (c) Does the Intervenor intend to offer-the testimony-3, 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. .

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s (d{ Does'the Intervenor disagree with the above I I statement due to the methodology through which its q

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. manner in which such methodology is flawed.

' Does the Intervenor disagree with the above (e)

"' 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. '

TEXAS-UTILITIES ELECTRIC COMPANY For the Owners of CPSES 2

• Thomas G./Dignan, Jr.

R. K. Gad.III.

,I William,S. Eggeling

. Kathryn A. Selleck S

ROPES &' GRAY -

225 Franklin Street 02110

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Boston, Massachusetts

-Telephone: (617)423-6100 Attorneys for Texas Utilities Electric Company s.

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L o? o coexEtte.

USNRC CERTIFICATE OF SERVICE

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in MNt -9 R2:49

'I, Kathryn A. Selleck, one of the attorneys.for the Applicants arricE er 9

.- herein, hereby certify that on March 5, 1987, I magggeavi.C.*tTAFY ce Pof f.the BRANCH within document by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Mr. James E. Cummins Chairman .

Resident Inspector Administrative Judge Comanche Peak S.E.S.

Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38

. Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge Midwest Office 881.W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street

i. U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555

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-.>% o Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel -

P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony'Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street ,

2000 P Street, N.W., Suite 611 Washington,.D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear-Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, 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 Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111 Kathryn A. Selleck

.