ML20102A383

Second Set of Interrogatories & Request to Produce Documentation Re Credibility.Certificate of Svc Encl.Related Correspondence

ML20102A383
Person / Time
Site:	Comanche Peak
Issue date:	02/04/1985
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
CON-#185-429 OL, NUDOCS 8502080336
Download: ML20102A383 (10)

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," s y. mW WiDmED CORRESPONDE.q 2/4/85 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00 gg In the Matter of I Docket Nos. 50-445 O TEXAS UTILITIES ELECTRIC l

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• g3ngg46N1 :33 COMPANY, et al. l

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-(Comanche Peak Steam Electric { Operatiniplidense)":/

Station, Units 1 and 2) { 'WM CASE'S SECOND SET OF INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE RE: CREDIBILITY Pursuant to the Board's 12/18/84 MEMORANDUM (Reopening Discovery; Misleading Statement) (pages 9 and 10), CASE (Citizens Association for Sound Energy), Intervenor herein, files this, its Second Set of Interrogatories to Applicants and Requests to Produce Re: Credibility.

Please answer the following interrogatories and requests for documents in the manner set forth herewith:

.1. Each interrogatory should be answered fully in writing, under oath

, or affirmation.

2. Each interrogatory or document response should include all pertinent information known to Applicants, their officers,.

directors, or employees, their agents,: advisors, or counsel.

-Employees is to be construed _in the broad sense of the word, r.

including specifically,' Brown and Root,.Gibbs & Hill, Ebasco, Cygna, 0. B. Cannon, any-consultants, sub-contractors, and anyone-else. performing work or services on behalf of the Applicants or their agents or sub-contractors.

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3.; The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts,

_p hotographs, reports, studies, audits, slides, internal memoranda, informal notes, _ handwritten notes, tape recordings, precedures, specifications, calculations, analyses, and any other data Leompilations from which information can be obtained.

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.4.- Each document provided should include a sworn statement of its authenticity.

5. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory. Do not 1

Jcombine answers.

6.. Identify the person providing each answer, response, or document.

7. These interrogatories _ and requests for documents shall be continuing in nature, pursuant to 10 CFR 2.740(e) and the past.

directives of.the Licensing Board. Because of the time

' restrictions under which we are presently working, we request that s

supplementation be 'made on an expedited basis.

-For each item supplied inf response to-a request for documents,

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-:85-identify it by the specific question number to which it is.in response. If the item is excerpted'from a documment, identify it _

also by the name of-.the document. _Please also: provide the copies

-in the correct order 1(rather than in reverse: order).

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, CASE'S INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE jf

' l .- (a) 'How'long have Applicants been committed to Manufacturers'

' Standardization Society (MSS) publication MSS SP-58 (" Pipe Hangers l!; - .and Support-Materials and Design")?

I(b): How long have Applicants been committed to Manufacturers' Standardization Society (MSS) publication MSS SP-69 (" Pipe Hangers

-and Supports-Selection and Application")?

((c) Was or is Applicants' commitment to-MSS SP-58 and/or MSS SP-69 contained in any document other than Design Specification 2323-MS-

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.(d). . If ' the answer. to (c) 'above is yes, list all other such documents.

Supply copies of the pages from Design Specification 2323-MS-46A

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.(e).

.which contain' Applicants' commitment to MSS'SP-58 and/or MSS SP-69

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[(including.the page which contains the Section on' Codes and.

Standards);fsupply~for the original.and each revision of MS-46A. ,

(These should be theJpages which correspond to pages 3-15 'through Me 3-20 of Revision ~5 of MS-46A.)

,U .(f)' Supply copies of the pages fron'ench of'the-documents. listed in-

. (d) preceding which.contain Applicants' commitment to. MSS SP-58 and/or MSS SP-69 (including the page which contains the section twhich sets forth the section); supply for the' original and each l revision of each document listed in (d) preceding.

/ (g)fHas there ever been any discussion, instructions, or-any other Lcommunication :(either orally or in writing) between Applicants and '

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.Cygna Energy Services regarding MSS SP-58 and/or MSS SP-697

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-(h) If the answer to (g) preceding is yes, supply copies of'all

, 1 documents (using the broad definition on page 2, item 3, of this pleading) by Applicants, Cygna, or anyone else regarding this matter. If not already indicated on the document (for instance, in the case of handwritten notes) supply the name of the person

~w hose notes they were, the person to whom the notes were written,

, and the date of such notes; i.e., include sufficient specific

(_ details so that-the document being supplied is readily

! understandable.

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!; (i) If the answer to (g) preceding is yes, but there are no documents u

in answer to (h) preceding, provide a brief statement containing

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/the details of such discussion, instructions, or other communication. Include specific details of who was involved in such communication, the date of each such communication, and a brief summary of the substance of such communication. Include

. sufficient specific details so that the information being supplied.

is readily understandable.

2. (a) Provide documentation that Applicants have provided Cygna Energy Services with all public documents from these proceedings regarding the Walsh/Doyle allegations.

(b) . Provide

. (i) a listing of all public documents (including pleadings, 3 9

Proposed Findings, etc., filed by CASE) which have been g 6

' provided to Cygna Energy Services (by Applicants or others);. [

7t (ii) all documents (such as cover letters,~aemoranda, etc.) by -3 g.

which such public documents were provided; .]

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(iii) if the documents were handed to Cygna on site, please so indicate; (iv) who (name, organization, and title) provided and who (name, organization, and title) received each such public dccument; (v) and the date on which each such public document was supplied to Cygna.

3.- (a) Provide documentation that Applicants instructed and/or contracted with Cygna Energy Services to address the design quality assurance issue.

(b) Provides (i) a listing of all documents (as defined on page 2, item 3 of this pleading), including contracts, which instruct and/or provide details to Cygna Energy Services as to which specific aspects of implementation of design quality assurance they are to address and/or how they are to address them; (ii) all documents (such as cover letters, memoranda, etc.) by which such documents were provided; (iii) if the documents were handed to Cygna on site, please so indicate;.

(iv) who (name, organization, and title) provided and who (name, organization, and title) received each such document;

.(v) and the date on which each such document was supplied to Cygna.

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- (c) Provide copies of all contracts, letters of understanding, or other instructions to or from Cygna as to the scope, criteria, protocol, and/or independence of Cygna's review and activities regarding Comanche Peak.

(d) Was there ever any kind of understanding (written or oral) to the effect that Cygna was to accept Applicants' representations at face value (similar to the agreement regarding J. J. Lipinsky's acceptance at face value of the statements made in Mr. Brandt's affidavit).

' (d) If the answer to (c) above is yes, provide all documents (as defined in item 3, page 2, of this pleading), including contracts, relating to such understanding.

If no documents exist, supply specific details of such understanding the name(s) (and organization and title) of each

-person with whom the professor discussed such understanding, a brief summary of all discussions, the date of each such discussion, and any other partinent'. details.

4. - (a) Provide documentation that Applicants have provided the professor discussed in Applicants' Plan with all public documents from these proceedings.

(b) Provides (i) a 11 sting of all publie-documents (including pleadings,

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Proposed Findings, etc., filed by CASE) which have been y provided to the, professor-(by Applicants or others);

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(ii) a listing of all other documents which have been provided to the professor; (iii) all documents (such as cover letters, memoranda, etc.) by

, which such documents were provided; (iv) if the documents were handed to the professor on site,

please so indicate;

-(v)' who (name, organization, and title) provided each such document; (vi) the date on which each such document was supplied to the professor; and

'(vii) all documents (as defined on page 2, item 3, of this pleading)' listed in (ii) preceding.

(c) Has the professor ever been on site? If so, provide specific-details of such site visit, including a listing of all documents reviewed, to whom he talked, a brief summary of all discussions onsite, the date of each site visit and discussion, and all documents (see definition under item 3, page 2 of this pleading)

. relating to each site visit.

(d) Provide copies of all contracts, letters of understanding, or

' other instructions to or from the professor as to the scope, criteria, protocol, and/or independence of the professor's review and activities regarding Comanche Peak.

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t (e) Nas there ever any kind of understanding (written or oral) to the effect that the professor was to accept Applicants' Erepresentations at face value (similar to the agreement regarding J. J. Lipinsky's acceptance at face value of the statements made in Mr. Brandt's affidavit)?

(f) If'the answer to (e) above is yes, provide all documents (as defined in item 3, page 2, of this pleading), including contracts, relating to such understanding.

If no documents exist, supply specific details of such understanding, the name(s) (and organization and title) of each person with whom the professor discussed such understanding, a brief summary of all discussions, the date of each such discussion, and any other pertinent details.

5. Provide copies of all damage studies for both Units 1 and 2 of Comanche Peak, and any and all related or similar documents (as defined on page

2,-item 3, of this pleading), including but not limited to those whielt relate to any unacceptable or questionable designs.

This is the second of several such requests which CASE intends to file under this Board Memorandum.

Respectfully submitted, Dm _ X f}L >

p's.)JuanitaEllis, President G SE (Citizens Association for Sound Energy) 1426 S. Polk, Dallas, Texas 75224 214/946-9446 b

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UNITED STATES OF AMERICA v NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }{

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TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-1

~ COMPANY, et al. }{ and 50-446-1

'(Comanche Peak Steam Electric }{

..g Station, Units I and 2) }{ ,

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CERTIFICATE OF SERVICE ,

s By my signature below, I hereby certify that true and correct copies of

, CASE's Second Set of Interrogatories to Applicants and Requests to Produce Re: Credibility havebeensentkothenameslistedbelowthis 4th day of February ,198 5 ,

.by: Express Mail where indicated by

• and First Class Mail elsewhere. d

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• Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West-Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.

'. Washington, D.C.' 20036

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• Judge Elizabeth B. Johnson Oak Ridge National Laboratory

• Geary S. Mizuno, Esq.

P. O.' Box X, Building 3500 Office of Executive Legal

. , - Oak Ridge, Tennessee 37830 '* Director U. S. Nuclear Regulatory Commission

• Dr. Kenneth A. McCollos, Dean -

f, - . D_ivision of, Engineering, Maryland National Bank Bldg. 2,r

~ Architecture and Technology - Room 10105 g Oklahoma State University:- 7735 Old Georgetown Rdad 1 Stillwater, Oklahoma' 74074' Bethesda, Maryland 20,8,14 1

• Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing L, 881.W.. Outer Drive ..

Board Panel  ;

0ak Ridge,. Tennessee 37830 U. S. Nuclear Regulatory Commission j' '

• Washington, D. C. 20555-

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Chairman , Renea Hicks, Esq.

'. Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division 1U. S. Nuclear Regulatory Commission Supreme Court Building L ' Washington, D. C. 20555 Austin.. Texas 78711 +

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Mr. Robert Martin Anthony Z. Roisman, Esq.

- Regional' Administrator, Region IV Trial Lawyers for Public Justice i tU. S.-Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plasa Dr., suite 1000 Washington, D. C. 20036 Arlington, Texasf76011 Mr. Owen S. Merrill Lanny A. Sinkin . Staff Engineer Executive Director Advisory Committee for Reactor E- Nuclear Information and Resource Safeguards (MS H-1016)

Service U. S. Nuclear Regulato'ry Commission 1346 Connecticut Avenue, N. W., Washington, D. C. 20555 4th Ploor ,

Washington, D. C. 20036 Dr. David H. Bolts 2012 S. Polk Dallas, Texas , 75224' Michael D. Spence, President Texas Utilities Generating Company

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Skyway Tower "

400 North Olive St., L.B. 81 i Dallas, Texas- 75201 1 .,

Docketing and Service Section (3. copies)

Office of the Secretary-U. S. Nuclear Regulatory Commission Washington, D."C. 20555 i

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O 222 - n / *,1 p .) Juanita Ellis, President WE (Citizens Association' for Sound Energy) 1426 5. Polk Dallas,: Texas 75224

$ 214/946-9446 l- l l .

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