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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 ML20087L3561992-04-0202 April 1992 Affidavit of Wj Jump Re Tj Saporito 2.206 Petition 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 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 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 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 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] |
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/N TSf UNITED STATES OF AMERICA tf g Q
M) p% JCLEAR REGULATORY COMMISSION 00(KETED USNRC
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u.s. p#dRSlRt3 E ATOMIC SA5'ETY AND LICENSING BdbDNOV 12 PS:55
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1/- / J PT SECRETARY l
\ __ . m g,G & SERVICE w ) MANCH l In the Matter of )
) Docket No. 50-498 .
IIOUSTON LIGHTING AND POWER CO. ) 50-499 (South Texas Project, Units 1 ) i and 2) '
) l CEU AND CCANP ADDITIONAL INTERROGATORIES TO IIOUSTON LIGHTING AND POWER COMPANY On Friday, November 6, 1981, CEU and CCANP hand delivered a set of joint interrogatories to llouston Lighting and Power Company pursuant to the Board's Order of October 30, 1981.
Although CCANP's written suggestions for interrogatories had been sent by Express Mail on Thursday morning, they did not arrive in the office of CEU's Counsel before close of business on Friday. CEU has examined those suggestions with a view to j eliminating any duplicative or overlapping questions so as l
to minimize the burden on IIL&P. CEU is serving these inter-rogatories by hand on Monday, November 9, which is equivalent to their having been served by CCANP by Express Mail on Friday, l November 6.
INTERROGATORIES l 15. Please provide a detailed daily schedule of how design and engineering work will be performed at the South Texas project i
for the period November 6, 1981, to March 1, 1982. If a daily schedule is not available, please provide the most complete
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schedule in HL&P's possession or of which it is aware. This question covers all aspects of design and engineering work, including site engineering and responses to questions raised by construction and QA/QC. In providing this schedule, please identify the company that will perform the design or engineering work and the specific or expected approximate date of any transsitions from one company to another.
- 16. Please state the basis for Houston Lighting and i Power Company's decision to terminate Brown and Root from the design, engineering, construction management, construction, quality assurance, and quality control aspects of the South Texas Project. Provide a specific explanation in each case, and provide all documents in HL&P's possession or available to HL&P concerning the decision to terminate Brown and Root.
- 17. Please state the conditions under which Brown and Root is authorized to hire additional personnel for work on the South Texas Project. In addition, please identify all areas of the Project for which either HL&P or Brown and Root has instituted a hiring freeze, state how long each such freeze has been in place, and the conditions under which it will be lifted or under which exceptions may be made.
Please provide all facts on which this answer is based and identify and provide copics of all documents related to or considered in providing this answer.
- 18. Please identify and restate all statements, whether cral or written, made to Brown and Root employees or prospective
L l .
employees since the Quadrex Report was commissioned concerning the benefits of emrjloyment with Brown and Root at the South Texas Project, the likely or promised tenure of their employment with Brown and Root (both at STP and elsewhere) , or the extent of job security for those employees at STP, whether with Brown and Root or some other company. Please provide copies of all documents in which these statements were made or in which these statements or job tenure or employee morale issues were discussed within HL&P or Brown and Root.
- 19. When were the final Quadrex Repori .d any drafts of the report received by HL&P? When did HL&P first become aware of the likely conclusions of the Quadrex Report?
- 20. When was the Quadrex Report first received by Brown and Root?
- 21. Please list, with an identification for each item as safetyrelated or nonsafetyrelated at the time of performance, all construction items performed:
- a. Since HL&P received the Quadrex Report.
- b. Since the date HL&P notified Brown and Root of HL&P's intent to terminate Brown and Root's responsi-bilities for any aspect of the South Texas Project.
- 22. Please list:
- a. All items of construction approved by the Nuclear Regulatory Commission for performance af ter the NRC received the Quadrex Report.
- b. The date each item was performed or the status of performance if still pending.
- 23. Please state:
- a. The two specific findings in the Quadrex Report that were reported by llL&P to the NRC pursuant to 10 CPR 550.' 55 (e) .
- b. The identities of all persons who participated in the decision making process that led to reporting these two items.
- c. The identities of the persons who participated in the decision making process that led to the release of the Quadrex Report to the Board and Intervenor representatives.
- 24. Please identify all measures taken to protect partially completed work at the South Texas Project during previous periods when work has been halted pursuant to stop work orders issued by the NRC, ilL&P, or Brown and Root.
25.. Please list any studies, reports, evaluations, or similar documents concerning possible deficiencies in either the construction or QA/QC programs at the South Texas Project prepared by the Bechtel Corporation or by any other entity. Please provide copies of any such documents not previously provided, a
]
Respectfully submitted, William S. Jordan, III IIARMON & WEISS 1725 I Street, N.W.
Suite 506 i
Washington, D.C. 20006 For Citizens for Equitable Utilities i __
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,,. ./,.
Lanny Sinkin . .
2207-D Nueces Austin, Texas 78705 For Citizens Concerned About Nuclear Power Dated: November 9, 1981 l
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tirJITl;li ::TATM;; n!' AMi:P lcA Nt!CI.MAH Hl; Gill.ATol(Y COMilI;;;;Iors lit:l'OHl; Tile ATOMIC ::Al'l:TY Atals 1.le l:II;; lilt; HOAltl, in the Matter of )
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IlOllSTON LIGilTING AND l'0WKH ) thai:he t il<,n . '.,0-498 01, cOllP ANY , e't al . , ) '. fi 4 '3'; og,
)
(South Texas Project, )
units 1 and 2) )
ciyT wy. cati: oP : i:avicE 1 hereby certify that copies of Citizens for Equitable Utilities and Concerned Citizens about Nuclear Power Ad-ditional Interrogatories to lionston Lighting and Power Company dated November 9, 1981, have been served on the following individuals and entities by deposit in the United Staten mail, first class, postage prepaid on This 9th day of November, 1981.
Char les pechhocfer, Esq. Isrian lie r w i e k , Eng.
Chict' Administ rative .Tak te Arin i n t an t Attorney Genere Atomic Safety and I,icensing for t.he State of Texas 110ard Panel Env i ronwrnt .il Protection u,S. Nuclear thylulatof y Commin:: on nivinion Wash i ng t on , D .C . 20555 P .o . Itox 1 F 4n, C..pitol
- t .it s on tr . James C . 1.amb, III Aunt i n , Toxian 78711
'Admi nis t rat ivo JtKkTO 313 Woodhaven Road *. lack H . tjewmaet , I; nth Chapel 11i11, N.C. 27514 f.ow'*nni i n , A x' 1 r ael , e t t 102', Connec ti cu t. Avenue,.
Ernest E. IlilI WUI' E "9 0 "" e U *C
- 2IJU 30 Admi n in t r.it I ve .I nth.f c Lawrence Livermore Lalx>ratos y Kim Eastman , Co-coordinal tiniversity of California narbara A . Mill er P .O . Ilox (1011, l.-123 Pat. Coy Livermose, Calatornia 94 % 0 Citizenn concerned About 11neIc.o l' owe r
'iIO(.,c.e:a oro San Ant.on io, Texan 7823
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- Mrs. Peggy Duckhorn f..inny :; ink i n executive pirector 2207-11 taus ren
,citizcna for Eqeitabic 7u 70',
utilitics, Inc. Aisnt i n . T. x.i:
Route 1 . Ik ,x 1 6 11 4 Dra:oria. Texas 77422 i
Jay ?!. Gu t.ierre z , Esq. At oni g. .;.i g ,,t.y and f.i cena i r>
Office of the Executivo q ,, ,, , , , 3 3 9,,,, ,3 Legal Director . .
U.S. Nuclear Regulatory Commission 11 ;t .11uct c.ir Hequlatory g9, ; ,;9 g ,,n Washingion, D.C. 20555 W.i th i nq i <>n , 1).C. 20555 Atomic S.itety and Licensing ik)cke t_ i nv. asiel Serrvice Sect iloard Office of Llie T.<cretary U.S. Nucicar Regulatory Conmis: tion U.S. lauclear Regul.itory tiaslii ng t on , D.C. 20555 Coimm i n:t i <>n W.i: hi nig tten , 12 .C . 2 0 'a S S T ,.l Willianil& IJordan, III IIARMON & WEISS 1725 I Street, N.W.
Suite 506 Washington, D.C. 20006 1