ML20042B245

Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc

ML20042B245
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/15/1982
From:	Doherty J DOHERTY, J.F.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-CP, NUDOCS 8203250136
Download: ML20042B245 (3)

Text

nom x re

' UNITED STATES OF AMERICA Marsh 15, 1982 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of:

HOUSTON LIGHT 7NG & POWER CO. DocketNo.50-466.{P p., g g g (Allens Creek Nuclear Generating Station, Unit 1) _

INTERVENOR DOHERTY'S MOTION TO SUBPOENA QUADREX CORPORATION EMPLOYEE WI'."NESSES FOR THE APRIL 1982 HEARINGS John F. Doherty, Intervenor in the above proceedings now files this motion for the Board to subpoena employees of the Quadrex Cornoration, identified in two Quadrer documents sub-mitted by Applicant in these proceedings, and would be con-trolled by the Board. Authority for the subpoena of a Board witness lies in the Appeal Board's decision ALAB-382, Conaumers Power Company, Midland Plant, Units 1 and 2, 5 NRC 603-608 g ,C 1977, at 607, where it stated: f <3 Nothing... precludes a Boardtfrom calling wi pggg nesses where it finds a genuine need for their Cf f

testimony or from utilizing Commission paymentsthe usual witness fee b

[T]he subjects which the witness may adress i .

testimony examination would be eparty by any controled wouldbybetherestricted in t he witness'.s direct presentation.

Board and to cro matist,'s. [@

(T{heBoard'sauthorityinthisrespectshouldbe exercised with circumspection where the witness it desires to hear would have been sponsored by one of the parties but for financial considerations.

Resumption of this proceedings is based on a filing by this Intervenor of December 7, 1981, and the Board's Order of January 28, 1982. Declining to leave the issue' of the Quadrex Report's implications for the ACNGS, as urged by Staff and Applicant, it stated at p.3:

If problems due to B&R's actions or inaction were encountered at STP despite HL&P'ssupervision the Board most certainly wants to know what specific corrective or preventative procedures HL&P will follow to assure that the problems will not recur I

at Allens Creek.

hO l 8203250136 820315 i PDR ADOCK 05000466 G PDR

s In response to this, this Intervenor would urge that the testimony of the actual authors of the Quadrex Report on the STNP, and the lately submitted Quadrex Report on the ACNGS are necessary-to have a clear under-standing of both B&R deficiene.ies despite HL&P supervision and to gain an ideal of what specific corrective or pre-ventative procedures should be followed.to prevent Droblem recurrence at Allens Creek.

Specifically, the two reports are at times difficult to understand, terse, and subject to interpretation. As an example of this last point, consider the fact that Appli-cant considered a "Most Serious Finding", to be a failure by Quadrex to observe evidence sufficient to conclude a particular systems function existed, / where other inter-pretations are quite possible. In addition, the Report covers seven engineering diciplines, using languaSe fre-quently idiosyncratic to it. In addition, the Board and parties may gain additional information from being able to examine the. persons who made the replies to the various report questions. These persons thus possess first hand experience with the replies which will permit them to fill out the (at times) sparse replies placed in the text of the Report.

Applicant will present t,wo witnesses according to its Counsel, Mr. Copeland on March 12th. These are Mr.

Goldberg of HL&P and Mr. Sas of Ebasco. Hence the Board and parties will not have the benefit of talking with any of the report's authors, themselves. While it is true, TexPIRG Additional Contention 31 has had a primary airing, the Quadrex Report, with its many determinations has vastly increased the scope of the Contention, such that there is serious doubt these witnesses can provide the detail and understanding that the actual authors would provide for this important issue.

$/Apolican'J s answer to Interrogatory 22, this Intervenor's first set of Quadrex related Interrogatories, March 8, 1982.

On the issue of Applicant technical qualifications, the Board and this Intervenor have been deprived of a full airing, because of an evident decision or omission by the Applicant and perhaps the staff to 'not-mention the report. This was noted by the Board in its Order of January 28, 1982 on p. 3. Here, this Intervenor urges that he not perhaps be subjected to the same happening by moving the Board require the appearance of ten witnesses all of whom have personal knowledge of the reports findings. By making these witnesses available to itself and the parties, the issue may certainly be aired fully.

Below, the names of each witness are presented, with the section of the Quadrex Report- they authored.

Those narked with an asterisk, also authored part of the shorter Quadrex Recort 'on Ebasco design work at Allens Creek, The letters in the last column refer to sections, in this Intervenor's " Motion for Additional Evidence on TexPIRG Additional Contention - 31, (Appli-cant's Technical Qualifications) of Decenber 7, 1981.

WITNESS NAME DISCIPLINE DEC. 7, 1981 MOTION SEC.

O. Houssain* Civil / Structural D, O J, Nardello Computer Codes G D. G. Scapini Electrical N Ram Bhat Heating, Ventil-ation & Air Cond. F,M D. Munson Mechanical Analysis F,N E. Willey* Mechanical N R. Uffer* . Nuclear D,F Gene Essewein* Piping J H. Booth Radiological G,J For the reason stated above, this Intervenor noves the Board subpoena on its own, the above witnesses, all of whom are authors in-part'of the Quadrex Report on the South Texas Nuclear Project.

espectfully,

& , Ms/82 John F. Doherty CERTIFICATE OF SERVICE: Certification of Service for this motion is with the enclosed, "INTERVENOR DOHERTY'S SIXTH SET OF INTERROGATORIES TO APPLICANT WITH REGARD TO TEXPIRG ADDITIONAL CONTENTION 31 AND-QUADREX RELATED-MATTERS.

l

_. _ _ _ _ _ _ _ _ _ - _ _ .