ML20107K262

Fourth Set of Interrogatories & Requests to Produce Re Credibility.Certificate of Svc Encl.Related Correspondence

ML20107K262
Person / Time
Site:	Comanche Peak
Issue date:	02/25/1985
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
CON-#185-781 OL, NUDOCS 8502280211
Download: ML20107K262 (50)

Text

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.- 2/25/85.

e e UNITED STATES OF AMERICA88CK8tEO (;)- ) "

• J NUCLEAR REGULATORY COMMISSION ;.w USNRC-BEFORE THE ATOMIC SAFETY AND LICENSING B0g FEB 27 P1 :44-

-In the Matter of I Docket Nos. 50-4a5 1

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TEXAS UTILITIES ELECTRIC' i D D Liat.3 ;ts gg COMPANY, et al. I NA

-- - (Application for an l

(Comanche Peak Steam Electric 1 Operating License) ~

Station, Units 1.and 2) {

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CASE'S FOURTH SET OF INTERROGAlund i T - - - - - =~s,-

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 Fourth Set of Interrogatories to Applicants and Requests to Produce Re: Credibility n/.

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

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.

M/. On 2/21/85, CASE sought and was granted additional time to file this pleading, from 2/21/85 until 2/25/85. CASE also sought and was granted additional time to file further discovery regarding tests and samples, from 2/28/85 until 3/4/85. Applicants and NRC Staff had no objections to thuse extensions.

1 8502280211 850225

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PDR ADOCK 05000445

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Employees is to be construed in the broad sense of the word, including specifically, Brown and Root, Gibbs & Hill, Ebasco, Cygna, O. B.l Cannon, any consultants, sub-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.

3. The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports', studies, audits, slides, internal memoranda, informal notes, handwritten notes, tape recordings, procedures, specifications, calculations, analyses, and any other data compilations from which information can be obtained.

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 i

combine answers. t

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 ,

supplementation be made on an expedited basis.

8. For each item supplied in response to a request for documents, identify it by the specific question number to which it is in 2

v e. .

respense. 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 (rather than in reverse order).

CASE'S INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE

1. Regarding p'otentially unstable supports:

(a) Supply a complete list of all supports which Applicants have ever identified as being potentially unstable. In your answer, include the location of each support. Also include a brief description of the history of each such support (i.e., when, why, how, and because of whom it first became potentially unstable; when, why, how, and by whom it was first identified as being potentially unstable; when, why, how, and by whom it was initially corrected; when, why, how, and by whom it was finally corrected); include sp,ecific dates, specific names, titles, and organization, and specific details.

Supply the requested information (1) for Unit I and common and (2) for Unit 2.

(b) . Supply drawings and calculations for each support listed in (a) preceding, at each step of the process (i.e., as the support was when it was first identified as being potentially unstable, when it was initially corrected, and when it was finally corrected).

(If any of this information has already been supplied, please specify the cover letter by which it was supplied, etc., in sufficient detail so that we can identify the information.)

(c) For each of the supports listed in your answer to (a) preceding, 3

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previde all documentation that Applicants identified such support as potentially. unstable, including copies of all deficiency paper (i.e., NCR's, CMC's, DCA's, IR's, and any other paper used by Applicants to identify such deficiency, 10 CFR 50.55(e) reports, etc.). Include all supporting documentation for such deficiency reporting,-as well as all documentation relating to the consideration of how to handle or correct the problem,-including all documentation relating to the final disposition of the problem.

Also include all documentation that each of the potentially unstable supports were included in trending.

(d) Which (identify by each support's number) of the supports listed

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in your answer to (a) preceding fit into each of the following categories?

(i) box frame with zero-inch gap attached to a single strut or snubber?

(ii) single strut with cinched-down U-bolt?

(iii) box frames modified by " indexed lugs"?

(iv) box frames modified by " additional struts"?

(v) box frames modified by cinching down U-bolt?.

-(vi) single struts with U-bolt t.ad a thermal gap?

(vii) single struts with U-bolt and a thermal gap, modified by ,

adding supplementary steel to create " stability bumpers"?

(viii) single struts with U-bolt and a thermal gap, modified by cinching 'down U-bolt?

(ix) double strutted frames supporting two or more pipes?

l (x) double strutted frames supporting a single pipe with 4

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.uncinch;d U-b31te?-

(xi) double strutted frames supporting a single pipe with cinched-down U-bolt?

(xii) double strutted trapeze supports with uncinched U-bolt?

(xiii) double strutted trapeze supports with cinched-down U-bolt?

(xiv) multi-strutted trapeze supports with uncinched U-bolt?

(xv) multi-strutted trapeze supports with cinched-down U-bolt?

(xvi) multi-strutted box frame? -

(xvii) single snubber with cinched-down U-bolt?

(xviii) double-strut, double-trunnion with uncinched U-bolt?

(xix) double-strut, double-trunnion with cinched-down U-bolt?

(xx) double strut trapeze with box frame?

(xxi) triple strut box frame?

(xxii) other configurations not specifically listed in the preceding?

Also supply any additional information which might assist in understanding the configurations discussed in the preceding.

(e) (1) Have Applicants considered the possibility that there may also be some potentially unstable cable tray supports?

(2) If the answer to (1) is yes, supply the same information for cable tray supports as was requested in (a), (b), and (c) preceding.

(f) In regard to Cygna's 2/19/85 letter 84042.035 to Mr. J. B. George, under Subject of Stability of Pipe Supports (copy of which is attached to CASE's 2/25/85 Notification of New and Significant Information and CASE's Supplement to CASE's 10/15/84 Motions and Answer to Applicants' Motion for Summary Disposition Regarding Stability of Pipe Supports, which is being sent in the same 5

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n mailing with this pleading):

(1) Supply a list of the supports which Cygna identified on page 7 (last paragraph) as:

(i) the'37 supports which, in the total absence of the pipe, are stable; (ii) the 124 supports which, in the absence of the pipe,

. would be unstable, but which'Cygna considers to I possess sufficient positive attachment to the pipe to ensure stability; and (iii) the 65 supports which Cygna considers to be potentially unstable.

, (2) Supply the drawings anl calculations which Cygna reviewed for each support listed in (1) preceding. (If these are already included in the Cygna Reports, please. indicate where they can-

. be found in the Report. If these are the same drawings and/or calculations supplied by Applicants in their answer to

.(b) preceding, please so indicate. Be specific.)

(3) Supply all drawings', calculations, or other documents (as-defined on page 2, item 3, of this pleading) generated by-Cygna or its agents in Cygna's review of each support listed' in (1) preceding. (If this has already been provided, please identify, for each support, the specific _ document provided.

and-the date_and Cygna identification number for each such cover letter'by_which it was provided.)

(4) Did Cygna attemp,t to ascertain whether or not Applicants had

. promptly identifed and corrected the problem of potential i: instability?

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(5)l.Did Cygna attempt to ascertain whether or not Applicants had trended each of the supports which were potentially_ unstable?

(6) If the answer to (4) and/or-(5) preceding is yes,-for each of the supports listed in your answer to (1) preceding, provide all_ documentation which Cygna reviewed which-indicated that Applicants identified such support as potentially unstable, including copies of all deficiency paper (i.e., NCR's, CMC's, D'CA's, IR's,.and any other paper used by Applicants to 1

identify such deficiency,, 10 CFR 50.55(e) reports, etc.).

f' Include all supporting documentation for such deficiency reporting,-as well as all documentation relating to the consideration of how to handla or correct the problem, including all documentation' relating to the final disposition of the problem.

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Also include'all documentat' ion that each of the potentially unstable supports were included in trending.

-(If any of this iniornation has already been provided-in-response to (c) preceding, please identify specifically which' such information reviewed by Cygna has already been supplied.)

(7) If the answer tx> (4). or (5) preceding is yes, what are-Cygna's_ current conclusions regarding the adequacy of Applicants' prompt identification and correction of the

. problem of instability, as well as the adequacy of Applicants' trending and whether or not such trending accomplishes the~ purpose of promptly identifying trends which

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may adversely affect quality?

(8) Which (identify by_each support's number) of the supports

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I reviewed by Cygna fit into each of the following categories j (this information is not clear from Cygna's listing at the top of page 8):

(i) box frame with zero-inch gap attached to a single strut or snubber?

(ii) single strut with cinched-down U-bolt?

(iii) box frames modified by " indexed lugs"?

(iv) box frames modified by " additional struts"?

s-(v) box frames modified by cinching down U-bolt?

(vi) single struts with U-bolt and a thermal gap?

(vii) single struts with U-bolt and a thermal gap, modified by adding supplementary steel to create

" stability bumpers"? (Answer appears to be 2; is this correct?) ,

(viii) single struts with U-bolt and a thermal gap, modified by cinching down U-bolt?

(ix) double strutted frames supporting two or more pipes?

(x) double strutted frames supporting a single pipe with uncinched U-bolts?

(xi) double strutted frames supporting a single pipe with cinched-down U-bolt?

(xii) double strutted trapeze supports with uncinched U-bolt? (Answer appears to be 3; is this correct?)

(xiii) double strutted trapeze supports with cinched-down U-bolt?

(xiv) multi-strutted trapeze supports with uncinched U-8

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bolt?

(xv) multi-strutted trapeze supports with cinched-down U-bolt? I l

(xvi) multi-strutted box frame? (Answer appears to be 8; is this correct?)

(xvii) single snubber with cinched-down U-bolt?

(xviii) double-strut, double-trunnion with uncinched U-

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bolt?

(xix) double-strut, double-trunnion with cinched-down U-bolt? (Answer appears to be 1; is this correct?)

(xx) double strut trapeze with box frame? (Answer

'- appears to be 2; is this correct')

(xxi) triple strut box frame? (Answer appears to be 1; is this correct?)

(xxii) other configurations not specifically listed in the preceding?

Also supply any additional information which might assist in understanding the configurations discussed in the preceding.

(9) Do Applicants agree that the copy of C;gna's 2/19/85 letter 84042.035 to Mr. J. B. George, under Subject of Stability of Pipe Supports, which was attached to CASE's 2/25/85 Notification of New and Significant Information and CASE's Supplement to CASE's 10/15/84 Motions and Answer to Applicants' Motion for Summary Disposition Regarding Stability of Pip ~e Supports (which is being sent in the same mailing with this pleading), is an authentic and correct copy of the letter received by Applicants from Cygna (with the 9

exception of the date on-which CASE received-the letter, which has been hand-written in the upper right-band corner of the letter)?

(10):If the answer to (9) precedi g is no, supply an authentic and

. correct copy of such letter.

(11) Does Cygna consider the 226 pipe supports which they reviewed as part of its Phases 2, 3 and 4 review to be a

. representative sample of the pipe supports at Comanche Peak?

(12) Do Applicants consider the 226 pipe supports which Cygna

. reviewed as part of its Phases 2, 3 and 4 review to be a representative sample of the pipe supports at Comanche Peak?

(13) If the answer to (12)-preceding is no, please explain in detail Applicants'= rationale for having chosen the-particular

-systems which they'had Cygna review to help alleviate the-

. Board's~ concerns about the design of Comanche Peak.

2. . .Regarding A500 Steel:

a.- Provide responses.to'the following,lwhich refer to the Affidavit of John C.' Finneran, Jr. Regarding A500 Tube Steel, which was attached to Applicants' 4/11/84 Response to Partial Initial Decision Regarding A500 Steel:

-(l) Affidavit beginning at bottom of.page 2, continuing on page 3:

(i) Provide documentation that Applicants recognized the reduction in yield strength.

(ii) Who were the people (supply individuals' names, titles, and organizations) who recognized the reduction in' yield

. strength?

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'(iii) Provide affidavits from the individuals listed in-(11)

' preceding that supports Applicants' statement at the' top

'of page 3 "that several factors in their pipe support

. designs assured that no adverse safety impact would result from their_use of the original yield strengths l

for A500 tube steel."

(iv) Include in the affidavits discussed in (iii) preceding the. credentials of each~such individual at the time their decisions were made.

(v) : Provide copies of all documents referred to by Applicants which contain the "several factors in their pipe. support' designs" which " assured that no adverse safety impact would result from their'use of the original yield strengths fc,r A500 ' tube steel." ~

-(2) -Affidavit at page 4:

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Supply calculations and-all other documentation which shows'a correlation between the 1/16"

-deflection criteria and stress in the tube steel which Applicants claim in most case's will limit the stress _in the supports.

(3) Affidavit at page 4:- Supply calculations and all other documentation which shows the stress limits in Hilti bolts .

will correlate with stresses in the tube steel.

(4) Affidavit'at page 5: Supply calculations, drawings, and all * +

other documentation which would indicate that the Applicants modified' supports while applying " level B stress allowables in assessing the more severe level C loads."

p (5) (i) Affidavit at page 5, last paragraph, continued on page 6: Supply copies of the test data, which Applicants l l --

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- s state is "provided to Applicants by fabricators of steel materials who perform material tests for various Lproperties, including yield strengths, on each production run of material," which would apply after the material has been welded to.

(iI) Do Applicants consider that the sample of pipe supports discussed at the top of page 6 was a randomly selected representative sample?

(iii) Provide documentation of the specific criteria which

-A'pplicants originally used.in selecting.the sample of-

-pipe supports discussed at the top of page 6.

(iv) Who (name, title, organization at the time) determined the specific criteria which Applicants originally used in selecting the sample of pipe supports discussed at the~ top of page 6?

(v) Who_(name, title, organization at the time) actually_

selected the specific pipe' supports included-in the sample of pipe supports discussed at the top of;page 67

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[(vi) Provide alll documentation-that=the supports assessed by

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Applicants were worst case supports.

(vii) Provide a list of all pipe supports included in the sample of pipe supports discussed at the top of-page 6.

'(viii) Provide a list of the pipe supports-from the sample identified in your answer to (vii) preceding which were considered by Applicants to be the worst case supports which Applicants " conservatively assessed."

( ix) Provide copies of all documentation (calculations,

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,o drawings,.etc.)'for each of the pipe supports listed in your answer to (vii) preceding.

(6)- (i)' Ik) Applicants consider that the sample of pipe supports discussed in the middle -paragraph on page 6 was a randomly selected representative sample?

(ii) Provide documentation of the specific criteria which Applicants originally used in-selecting the sample.of pipe supports discussed in the middle paragraph on page 6.

(iii).Who (name, title, organization at the time) determined the specific criteria which Applicants originally used in selecting the sample of pipe supports discussed in the middle paragraph on page 6?

(iv) Who (name, title, organization.at the time) actually selected the specific pipe supports included.in the sample of pipe supports discussed in the middle paragraph on page 6?

(v) . Provide all documentation that the supports assessed by.

Applicants were worst case supports.

(vi) Provide a list of all pipe supports included in the sample of pipe supports discussed in the middle paragraph on page 6. .

(vii) Provide copies of all documentation (calculations, drawings, etc.) for each of the pipe supports listed in your answer to (vi) preceding.

(7) Affidavit at page 7

Supply the support numbers, calculations, and drawings for all supports which required modification in the vendor certification process due to the l.

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-tube steel member's being overstressed.

(8) : Affidavit at page 8: Provide documentation from ASME or the ASME code that supports Applicants' that there will be only a "13% reduction in yield strength" when the tested tube steel member's yield value is above the "42 ksi yield strength value originally published."

(9) Affidavit at page 8: Provide all documentation of the basis for the assurance which Applicants claim to have that the tube steel material which is tested at 56.3 kai will not have a yield' strength value of 36 kai (or less) after welding.

(b)- The following relate to page 5 of Applicants' 4/11/84 Response to Partial Initial Decision Regarding A500 Steel, page 5, Footnote 6:

(1) Provide documentation showing the contract dates for all piping on which tube steel supports are used.

(2) Provide documentation showing-the original contract dates for ITT Grinnell, NPSI, and PSE for all supports within their scopes and all supports that were transferred from one organization's scope to another's.

(3) Provide documentation showing dates of an. approval to revision 0 to the design criteria for NPSI, ITT Grinnell, and PSE for Comanche Peak.

(4) Provide documentation that there was mutual consent of the owner, manufacturer, and installer that Applicants need not consider ASME Code Case N-71-10 on those supports designed, ordered, and fabricated after May 11, 1981.

?3. .Regarding AWS vs. ASME:

a._ With regard to Affidavit of J. C. Finneran, R. C. Iotti and J. D.

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- Stevenson Regarding Allegations Involving AWS vs. ASME Code f :' Provisions, Attachment 1 to Applicants' 5/17/84 Motion for Summary.

. Disposition of Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to Design, Issues:

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. (1) Beginning on page 4 of the Affidavit, Applicants' affiants

! ' discuss at some length the provisions of Appendix XVII, paragraph 221(c) of Section III of the 1974 ASME Code:

(i) ' Where is it stated in ASME that this is a compensatory -

requirement?

J (ii) Isn't it a fact that. Appendix XVII, Paragraph 2211(c) was subsequently deleted in the Winter 1978 Addenda? ,

(iii) Isn't it also a fact that Applicants adopted the deletion of Appendix XVII, Paragraph 2211(c)?

(iv)-What was the purpose of Applicants' discussion of Appendix XVII, Paragraph 2211(c), in their Affidavit, a

and how~was it relevant to the issue under discussion?

' (v) Why didn't Applicants' affiants state that Appendix-

! XVII, Paragraph 2211(c), had been subsequently deleted and that such deletion has . been adopted by the

Applicants?

4.. Regarding axial restraints:

e s.- . On page 39 of the SIT Report (which was conducted October 13-December 2,1982 and January 18, 1983), it is stated that:

i - " Subsequent discussions with the Applicant indicated that this rotational. restraint had also been identified during the Applicant's normal design review and that the pipe stress

, analysis was being modified to consider this rotational restraint."

However, Applicants have now changed their position on this (as indicated on pages 3 and 4 of the Affidavit of Robert C. Iotti and '

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John C. Finneran, Jr. Regarding Consideration of Force Distribution in Axial Restraints, which was attached to Applicants' 7/9/84 Motion for Summary Disposition Regarding Allegations Concerning Consideration of Force Distribution in Axial. Restraints.

Regarding this:

(1) What has changed since Applicants told the SIT that they were going to modify their pipe stress analysis to consider-this rotational restraint? Provide specific details.

(2) Provide all documents (as defined on page 2, item 3, of this pleading) which indicate that Applicants had advised the NRC of Applicants' change in position regarding this prior to 7/9/84.

5. Regarding damping factors:

-a. Regarding the Affidavit of Robert C. Iotti Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions, which was attached to Applicants' 5/16/84 Motion for Summary Disposition Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions:

(1) l Affidavit at page 4: Dr. Iotti discusses a statement in the SIT Report at page 48:

"The Special Inspection Team concluded'that these response spectra characteristics, together with the fact that the SSE damping value of 4 percent is twice the OBE damping value of 2 percent led to the condition expressed in Mr. Doyle's concern."

Dr. Iotti then states that "The SIT was not clear that the use of 2 and 4 percent damping factors in the analysis of OBE and SSE conditions to which it refers was with respect to 16

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that aspect of the analysis in which closely spaced modal responses are combined using a coupling factor."

(i) When (specific date") did Dr. Iotti begin working on this issue for Comanche Peak?

(ii) What was the basis for Dr. Iotti's conclusion that "The SIT was not clear . . . " Did someone tell him? If so, who (name, title, and organization),

'and what was the basis for such individual's conclusion? Did Dr. Iotti discuss this matter with anyone on the SIT or with the NRC? Uid Dr. Iotti assume that the SIT had meant to say something else in the SIT Report? Give specific ~ details as to his basis.

(iii) Provide all documents (as defined on page 2, item 3, of this pleading) whier indicate that Applicants-or any of their agents informed the SIT or the NRC that "The SIT was not clear . . . " regarding this

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matter, as well as all documents relating to the SIT's or the NRC's response (s).

6. Regarding Differential Displacements:

a. Regarding the Affidavit of R. C. Iotti and J. C. *Finneran, Jr.

.Regarding Differential Displacement of Large Frame Pipe Supports,

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Attachment I to Applicants' 6/22/84 Motion for Summary Disposition i of CASE Allegations Regarding Differential Displacement of Large-Framed, Wall-to-Wall and Floor-to-Ceiling Pipe Supports:

On page 7 of the Affidavit, Applicants' affiants discuss the 17

'.' prompt ' attention" the problem received:

(1) Provide all documents (as defined on page 2, item 3, of this '#

pleading) indicating that the problem received prompt attention, including all deficiency paper and its A disposition.

-(2) Provide the justification for proceeding with construction of these supports even though'they were known to be "not in strict compliance with the PSE guideline" (i.e., what procedure gives Applicants the authority to ignore such guidelines, on whose authority was such a decision made (name, title, organization), etc.).- (We have read what is said in Applicants' Affidavit, so you need not repeat what is said there in answer to this question.)

(3) 'Why should the Licensing Board believe that this problem .

r would have been adequately resolved if the SIT had not raised the issue?

(4) ,In Applicants' Affidavit, they state that "only these four supports were in violation of the guideline." They further ,

state (page 8) that Applicants (at the recommendation of the' '

-SIT) made the guideline regarding this issue applicable to

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ITT and NPSI. 5 If the same PSE Guideline had also been in effect prior to that time for 1TT and NPSI, would there have been additional ITT and NPSI supports which would have been in violation of the guideline?

(5) Provide all documents.(as defined on page 2, item 3, of this pleading) in support of your answer to (4) preceding.

(6) Have Applicants or any of their employees (as defined on 18

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- pages 1 and 2, item 2, of this pleading) subsequently discovered additional supports which would have been in

- violation of the PSE Guidelines in effect during the time

-period discussed in the preceding (i.e., 1981-1982)?

-(7) If the answer to (6) preceding is yes, supply- a list of, and complete details and'all documents regarding, each such support.

(8) On page 26 of the SIT Report (first full paragraph), it states:

"During the course of the inspection, the Applicant informed the Special Inspection Team that these supports would be unable to withstand differential seismic displacements and were being redesigned."

Considering this statement, what was the basis for Applicants' belief (discussed.on page 7 of the Affidavit)

- that "the designs, although not in strict compliance with the PSE guideline, were adequate"?

(9) Who (name, title, organization) made the statement (quoted in (8) preceding) to the SIT? Is this individual (or individuals) still employed at Comanche' Peak? If not, supply such individual (s) last known address and telephone number.

,. -(10) Provide all documents which led such individual (s) to the conclusion that "these supports would be unable to withstand ,

differential seismic displacement."

(11) Provide all documents (including detailed analyses) which reflected that "similar supports designed by ITT and NPSI" "were adequate including consideration of differential seismic displacement" (as stated on page 8 of Applicants' Affidavit).

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7. Regarding Richmond Inserts:

, a. Answer the following questions regarding the Affidavit of John C.

Finneran, Jr. , Robert C. Iotti and R. Peter Deubler Regarding Design of Richmond Inserts and Their Application to Support Design (Attachment 1 to Applicants' 6/2/84 Motion for Summary Disposition Regarding Design of Richmond Inserts and Their Application to Support Design):

(1) On page 27 of the Affidavit, a bolt interaction equation is given. Provide all documents (as defined on page 2, item 3, of this pleading) which gives the basis for this equation (i.e., design guidelines, specifications, procedures, codes, standards, recognized authorities, etc.).

(2) With further reference to (1) preceding, why isn't the tensile stress due to bending added to the direct tensile stress T?

(3) On page 25 of the Affidavit, Applicants' affiants discuss an interaction value of 1.75. Where else within the industry is an interaction value greater than 1 considered to be acceptable? Provide all documents (as defined on page 2, item 3, of this pleading) which support the acceptable of an interaction value greater than 1 (i.e., design guidelines, specifications, or procedures other than for Comanche Peak, codes, standards, recognized authorities, etc.).

8.- Regarding the upper lateral restraint:

a. Isn't it true that LP'.A "as not considered in the original design of the upper la'.e- 4 -( raint?

b. What was Applicants' rationale for not considering LOCA in the 20 .

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original design of the upper lateral restraint?

c. Provide all documents (as defined on page 2, item 3, of this pleading) regarding your answer to b. preceding.

9. Regarding cable tray supports: ,

a. Are cable tray supports / hangers considered to be safety-related?

b. Isn't it true that all cable tray supports at Comanche Peak have one original generic design?

c: Isn't it true that the effects of.a loss-of-coolant accident (LOCA) were not considered in the original generic design of cable tray supports?

d. What was Applicants' rationale for not considering the effects of a LOCA in the original generic design of cable tray supports?

e. Have Applicants now considered LOCA in the generic design of cable tray supports?

f. If Applicants have considered LOCA in the generic design of cable

_ tray supports, provide all documents which confirm this.

g. Isn't it true that Applicants have neglected to consider the-reduction of the yield point during a LOCA on any steel member on a cable tray support within the containment? ,

h. What was Applicants' rationale for neglecting to consider the' reduction of the yield point during a LOCA on any steel member on a cable tray support within the containment? ,

i. Were the samples of cable tray supports which Cygna reviewed representative of the cable tray supports within the containment?

j. Isn't it correct that the same generic design was used for cable tray supports within the containment as was used for the cable tray supports which Cygna reviewed?

k. Isn't it correct that the FSAR requires that cable tray supports 21 9

r within the containment must consider the effects of LOCA?

1. Isn't it correct that Applicants have not considered the effects of multimodal responses in the design of cable tray supports?

' ~

m. For what other systems or components have Applicants not I considered the effects of multimodal responses?

n. Isn't it correct that Applicants did not use the peak of the response spectra curve in their reanalysis in response to Cygna's questions in Phases 1 and 2?

o. If the answer to n. preceding is yes, what was Applicants' rationale for not doing so?

p. Has any technical audit by Gibbs & Hill, TUSI, or any other agent of Applicants identified that the Applicants have not utilized the 1.5 multimodal response factor?

q. If the answer to p. preceding is no, what is Applicants' explanation for this?

_ r. What have Applicants done since this was brought to Applicants' attention by CASE Witness Mark Walsh (through the May 1984 hearings) insofar as checking to see whether Applicants have also failed to utilize the 1.5 multimodal. response factor for systems and components'other than cable tray supports? Provide all documents (as defined on page 2, item 3, of this pleading) regarding this.

s. Have any technical audits or any other kind of audit, report, review, etc., been done to determine this? If so, provide all such documents (as defined on page 2, item 3, of this pleading).

t. What was Applicants' rationale for utilizing a normalization process (see Tr. 13,179/11-18) in the design of cable tray 22

' _m .

r:- 1

c. . -.

supports which did not include the effects due to the SSE condition on the Hilti bolts?

u. What have Applicants done to verify that the Hilti bolts will meet manufacturers' recuirements (i.e. , a . factor of. safety of 4) under an SSE loading condition? Provide all documents regarding this,

v. What calculation has been used to verify the Hilti bolts will meet

.the manufacturers' standard of a factor of safety of 4 under an

'SSE loading condition? Provide all documentation of this.

v. On what other systems and/or components within the plant did

' Applicants or their agents utilize this normalization process?

Provide all documents regarding this.

x. Isn't'it correct that Applicants utilized a. factor of 1.6 Fy under the SSE loading condition in the' generic designs for cable tray supports?

y. . Isn't-it correct that Applicants' FSAR states that steel structures within the containment cannot have stresses above .9 Fy

'under the SSE loading condition in tension and bending?

z. Since steel structures within the containment cannot have stresses above .9 Fy under the SSE loading condition (according to Applicants' FSAR) in tension and bending, what was Applicants' rationale for utilizing the generic designs for cable tray-supports which, when exercising Applicants' normalization process, would not exercise the limitation of stress under an SSE loading condition?

4 aa. What did Applicants do to those cable tray supports which were overstressed as discusaed in the May *984 hearings? Provide all documents regarding this.

10.. Supply all documents (as defined on page 2, item 3, of this pleading) 23

s.

• relied'upon in any way it the testimony of Applicants' witnesses who testified during the February and March 1984 welding hearings (both in the welding hearings and in the intimidation hearings regarding Henry or Darlene Stiner). (If there is any doubt as to what specif'ic documents we are requesting, contact Juanita Ellis for specific

' details.)

11. With regard to Applicants' welding witnesses (who testified either in the September 1982 or February / March 1984 welding hearings, or had depositions taken or testified in the intimidation hearings regarding Henry or Darlene Stiner), provide the following information for each Applicants' witness:

How many hours did Applicants' or Brown & Root's attorneys spend

~

a.

with the witness? How long was each session? Give a specific time frame, including specific dates and times of day or night.

b. Was the witness given any assignments in preparation of testifying?

c. During the time when Applicants' or Brown & Root's attorneys were preparing the witness, were the following individuals also present:

(1) Ron Tolson?

(2) Tom Brandt?

~

(3) W. E. Baker?

(4) David Chapman?

(5) Antonio Vega?

(6) Any of the witness's superiors (if so, supply the name(s), title (s), and organization (s) of each)?

(7) Anyone else (if so, supply the name(s), title (s), and 24

organization (s) of each)? .

d. - How much time did'the witness spend at work in preparing his testimony? How much overtime did the witness spend in preparing his testimony? How much time on week-ends or during his time off from work did the witness spend in preparing his testimony?

e. Provide for: inspection and copying copies of the witness's time sheets (or whatever means is used to indicate the date, time, and number of hours worked) for the three months before and the three months af ter each time the witness testified.

-f. .How was it decided-that the witness should testify (i.e., did he come to someone and say he wanted to testify, was he asked by

-someone to testify, was he told by someone that he would testify, etc.)? Give specific details, including who (name, title, organization) the witness individually :alked to, who he talked to subsequently, etc.

g. Provide all documents (as defined on page 2, item 3, of this pleading) regarding your answer to f. preceding.

h. Has the witness had a change in shifts, position, pay. scale, etc.,

'between July 1,-1982, and the present? Supply complete details, including all. documents (as defined on page 2, item 3, of this pleading, and including specifically job performance ratings, counseling reports, etc.) regarding all such changes. Include specifically information regarding the status of Cliff Brown.-

1. Has the witness-quit or been terminated since he testified? If so, supply. complete details, including all documents regarding this (including job performance ratings, termination slips, counseling reports, exit interviews, etc.). Also include the witness's last known address and telephone number. Include 25

specifically information regarding the status of Cliff Brown.

j.- Supply all documents regarding where the witness worked, who his immediate superior was, what crew he was on, during the time Henry

~

and Darlene Stiner worked at Comanche Peak. Also state how the witness's job changed from his former position.

k. Which other welding witnesses were on the same crew as the witness at the time, or within six months of the time, the witness testified? Identify each such other witness by name. Also specify the times during which each other welding witness was on the same crew as the witness.

1. Was the witness promised, or was it implied that he would receive, anything if he testified or for his testimony (for instance, free representation by Applicants' or Brown & Root's counsel if he got into trouble, transfer to the work he wanted to do, a raise, extra vacation benefits, extra time off, other long-term benefits, etc.)? If so, what specifically was he promised, or was it implied that he would receive? Was the promise or implication fulfilled? Give all relevant details. Provide all documents (as defined on page 2, item 3, of this pleading) relating to this.

m. Were there any notes, tapes, or other documents (as defined on page 2, item 3, of this pleading) of meetings, discussions, etc.,

regarding the witness's preparation for testifying?

n. If the answer to m. preceding is yes, provide all such documents.

o. If a copy of his resume was not' supplied at the time he testified, supply a copy now.

p. Has the witness ever spent any time in jail? Does the witness have a criminal record? If the answer is yes, give specific 26

details and supply all documents (as defined on page 2, item 3, of this pleading) regarding this. If the answer is no, describe what specific steps Applicants took to ascertain this; provide all documents regarding this. ,

q. Has the witness ever been involved in any way with drugs, either onsite or offsite? Has the witness ever spent any time in jail for drug use or the sale of drugs? Does the witness have a

' criminal record regarding the use or sale of drugs? Was the witness terminated regarding the use or sale of drugs? If the answer-to any of the preceding questions is.yes, give specific details and supply al1~ documents (as defined on page 2, item 3, of' this pleading) regarding this. If the answer is no, describe what specific steps Applicants took to ascertain this; provide all documents regarding this.

12. With regard to all other of Applicants' witnesses (who had depositions taken or testified in the intimidation hearings, or testified in the other portion of the hearings, or filed affidavits including but not limited to regar' ding the Walsh/Doyle issues) provide the following

- information for each Applicants' witness (if he/she testified more than once, for each time he/she testified, if applicable):

a. How many hours did Applicants' or Brown & Root's attorneys spend with the witness? How long was each session? Give a specific time frame, including specific dates and times of day or night.

b. Was the witness given any assignments in preparation of testifying?

c. During the time when Applicants' or Brown & Root's attorneys were preparing the witness, were the following individuals also present:

27

a +

(1) Ron Tolson?

(2) Tom Brandt?

(3) W. E. Baker?

(4) David Chapman?

(5) Antonio Vega?

(6)- Any of the witness's superiorr; (if so, supply the name(s), title (s), and organization (s) of each)?

(7) Anyone else (if so, supply the name(s), title (s), and organization (s) of each)?

d. 'How much time did the witness spend at work in preparing his testimony? How much overtime did the witness spend in preparing his testimony? How much time on week-ends or during his time off from work did the witness spend in preparing his testimony?

e. Provide for inspection and copying copies of the witness's time sheets (or whatever means is used to indicate the date, time, and

number of hours worked) for the three months before and the three months after each time the witness testified.

f. How was it decided that the witness should testify (i.e., did he come-to someone and say he wanted to testify, was he asked by someone to testify, was he told by someone that he would testify, etc.)? Give specific details, including who (name, title, organization) the witness individually talked to," who he talked to subsequently, etc.

g. Provide all documents (as defined on page 2, item 3, of this pleading) regarding your answer to f. preceding.

h. Has the witness had a change in shifts, position, pay scale, etc.,

between July 1, 1982, and the present? Supply complete details, 28 .

e - ,r. . - ~ . . . _ - . - , , . , , ,_ _ . - . . . - - . . -- + , - , - ~ -, m ,- y -e- -- ,- ,.

a - --.

P including all documents (as defined on page 2, item 3, of this pleading, and including specifically job performance ratings, counseling reports, etc.) regarding all such changes. Include specifically information regarding the status of Gordon Purdy,

' Thomas Brandt, Antonio Vega, David Chapman, Ronald Tolson, the "somewhat knowledgeable" engineers referred to by John Finneran.

i. Has the witness quit or been terminated since he testified? If so, supply complete details, including all documents regarding this (including-job performance ratings, termination slips, counseling reports, exit interviews, etc.). Also include the witness's last known address and telephone number. Include specifically information regarding the status of Gordon Purdy, Thomas Brandt, Antonio Vega, David Chapman, Ronald Tolson,'the "somewhat knowledgeable" engineers referred to by John Finneran.

j . Supply all documents regarding where the witness worked, who his immediate superior was, what crew he was on, how the witness's job differed from his previous job.

k. Was the witness promised, or was it implied that he would receive, anything if he testified or for his testimony (for instance, free representation by Applicants' or Brown & Root's counsel if he got into trouble, transfer to the work he wanted to do, a raise, extra j vacation benefits, extra time off, other long-term benefits, etc.)? If so, what specifically was he promised, or was it implied that he would receive? Was the promise or implication fulfilled? Give all relevant details. Provide all documents (as defined on page 2, item 3, of this pleading) relating to this.

1. Were there any notes, tapes, or other documents (as defined on i.

- page 2, item 3, of this pleading) of meetings, discussions, etc.,

29 1

9

--->r.., - ,, , -- - , - -n, - ,ar-- .,,~..,,.,n .m.,,--.--.~.,..--,-..-._,,-n ,.,,,.-n.. - - , ,s-w.-.-r --, ,.,---me

regarding the witness's preparation for testifying?

m. If the answer to 1. preceding is yes, provide all such documents.

n. If a copy of his resume was not supplied at the time he testified,

~

supply a copy now.

o. Has the witness ever spent any time in jail? Does the witness have a criminal record? If the answer is yes, give specific details and supply all documents (as defined on page 2, item 3, of' this pleading) regarding this. If the answer is no, describe what specific steps Applicants took to ascertain this; provide all documents regarding this.

p. Has the witness ever been involved in any way with drugs, either onsite or offsite? Has the witness ever spent any time in jail for drug use or the sale of drugs? Does the witness have a criminal record regarding the use or sale of drugs? Was the witness terminated regarding the use or sale of drugs? If the answer to any of the preceding questions is yes, give specific details and supply all documents (as defined on page 2, item 3, of this pleading) regarding this. If the answer is no, describe what specific steps Applicants took to ascertain this; provide all documents regarding this.

13. Is James Stembridge still employed at Comanche Peak? If the answer is no, did he quit or was he terminated? If the answer is no, provide all details and documents (as defined on page 2, item 3, of this pleading),

including specifically (but not limited to) job performance ratings, termination slips, counseling reports, exit interviews, etc. Also provide his last known address and telephone number.

14. Provide copies of Henry Stiner's personnel records, including but not 30

limited to certifications, eye examinations, job performance ratings, termination slip, counseling reports, exit interviews, etc.

(Applicants will be provided with a signed notarized release by Henry .

Stiner.)

15. Provide copies of Darlene Stiner's personnel records, including but not limited to certifications, eye examinations, job performance ratings, termination slip, counseling reports, exit interviews, etc.

(Applicants will be provided with a signed notarized release by Darlene Stiner.)

16. Supply documentation that Armund Braumuller had been a welder for 28 years at the time he testified in the March 1984 hearings.

17. Isn't it a fact that Applicants do not routinely check to ascertain whether or not an employee or a potential employee has a criminal record or is involved in the use or sale of drugs?

18. Isn't it a fact that Applicants normally do not check to ascertain whether or not an employee or a potential employee has a criminal record or is involved in the use or sale of drugs unless they plan to attempt to discredit him, for instance if he/she is testifying in a DOL case against Brown & Root or the Applicants, or in an operating license hearing?

19. If the answer to 17 or 18 preceding is no, answer the following questions regarding Henry Stiner:

a. When and how did Applicants first become aware that Mr.

Stiner had a criminal record?

b. Provide all documents (as defined on page 2, item 3, of this pleading) which~ support your answer to a. preceding.

20. If the answer to 17 or 18 preceding is no, answer the following

questions regarding William Dunham

31 I'

L

a. When and how did Applicants first become aware that Mr.

Dunham had a criminal record?

b. Provide all documents (as defined on page 2, item 3, of this pleading) which support your answer to a. preceding.

21. If the answer to 17 or 18 preceding is no, provide details, and all documents (as defined on page 2, item 3, of this pleading) regarding, what techniques and methods Applicants usually employ to check out whether or not an employee has a criminal record or has been involved in the use or sale of drugs. Is there a procedure which sets forth Applicants' policy in this regard; if so, provide it (original and all revisions).

22. Provide the basis and all documents (as defined on page 2, item 3, of this pleading) for.your answer to 21. preceding.

23. During a conference call (CASE believes it was 9/30/84), the Licensing Board ordered Applicants and NRC Staff to respond to the susstantive portions of CASE's interrogatories and requests to produce regarding drug use at Comanche Peak. Provide Applicants' response now.

24. a. Isn't it true that virtually all of the supports in the North Yard Tunnel have now been changed due to design changes?

b. Isn't it true that many or most of the changes referenced in a.

preceding were made to floor-to-ceiling hangers? .

c. Isn't it true that many or most of the changes referenced in a.

preceding were to change the hangers so that they now have slip joints?

d. Isn't it true that many or most of the changes referenced in a.

preceding were made in response to the Walsh/Doyle allegations?

32

n- -

l 3

e.- Isn't it true that the change to slip joints was one of the recommendations made by Messrs. Walsh and/or Doyle in the operating license proceedings?

f. Provide a list of all supports / hangers in the North Yard Tunnel which have been modified or redesigned; include in your answer whether or not such supports are safety-related, the class of each support, and the system of which each support is a part.

g. Provide drawings and calculations (the ones just prior to the change, and the ones where the change was made) for each support / hanger listed ir '

preceding. Also provide any other documents (as defined on page 2, item 3, of this pleading) relating to such change.

h. For each support / hanger listed in f. preceding, state exactly how the support was changed and the specific reason for the change,

i. (i) How many other hangers / supports have been modified or redesigned in response to the Walsh/Doyle allegations?

(ii) Supply a list of all such supports, each supports's location, the system each support is part of, whether or not each support is safety-related, and the class of each support, and the system of which each support is a part.

(iii) Provide drawings and calculations (the ones just prior to the change, and the ones where the change was made) for each '

support / hanger listed in (ii) preceding. Also provide any other documents (as defined on page 2, item 3, of this pleading) relating to such change.

(iv) For each support / hanger listed in (ii) preceding, state exactly how the support was changed and the specific reason for the change.

33 L_

e 4

25 - a.- List each and every method which has ever been used by Applicants to identify nonconforming conditions. For each such method, include in your answer:

(1) Whether or not the method is still being used.

(2) The time period during which the method was/has been used.

(3) Whether the method is used for construction or for design, or both.

.(4) Whether or not the method is trended.

~~

(5) The time period during which the method was/has been .

trended.

(6) Provide all documents (as defined on page 2, item 3, of.

this pleading) setting forth the criteria for which method is to be used. Include the original and all revisions of each specification, procedure, instruction, memo, etc. relating to this.

(7) ~ Provide all documents (as defined on page 2, item 3, of this pleading) which substantiates that each method has been/is being trended.

(8) How many documents (NCR's, DDR's, etc.) have been generated over the life of the plant for each such method?

(9) How many items are still open at the present time of documents generated for each such method?

-(10) Include the various punch lists in your responses to items 1 through 9 preceding.

b. In the past, have non-conforming designs been issued to the field 34

<<7  ;

4 and' constructed before the original design organization completes

.c .

its review of changes (such as those made by CMC, DCA, etc.)?

(1). If the answer is yes, is this still being done?

-(2) If the answer to (1) preceding is no, provide all documents (as defined on page 2, item 3, of this pleading) which relates to this change of policy,

, procedure, or practice.

c. Provide all documentation that Cygna was to have reviewed the adequacy of Applicants' implementation of design QA. Give specific and complete details.

d. Provide a brief summary of Applicants' current position regarding the identification and correction of non-conforming designs. Give specific and complete details.

e. If it has not already been provided in response to another question, provide all documentation of Applicants' present position regarding the handling of non-conforming designs, including the identification and correction of such non-conforming designs.

f. Provide copies of all CAR's and SDAR's (and all other documents which may be used to identify significant deficiencies or l

potentially significant deficiencies) and all documents which relate to each.

g. Provide copies of all CAR and SDAR logs (and logs for all other documents which may be used to identify significant deficiencies).

h. Provide copies of all, procedures, instructions, menos, etc. which set forth how the determination is made as tot whether or not a deficiency is significant, when it is to be reported to the NRC,

~

35 L _

c .

,-.:+ .

\

who is to made such determinations, etc. Provide the original and all revisions for each such document.

i. Who (name, title, organization) is authorized to made the determinations discussed in h. preceding? Who (specifically) has been authorized to made such determinations in the past. Include in your answer the specific time periods during which each such individual was so authorized.

~

j. List each and every method which has ever been used by Applicants or their employees (as defined on pages 1 and 2, item 2, of this pleading) to make design changes. For each such method, include in your answer:

(1) Whether or not the method is still being used.

. (2) The time period during which the method was/has been used. ,

(3) Whether the method is used for construction or for design, or both.

(4) Whether or not the method is trended.

(5) The time period during which the method was/has been trended.

(6) Provide all documents (as defined on page 2, item 3, of this pleading) setting forth the criteria for which method is to be used. Include the original and all revisions of each specification, procedure, instruction, memo, etc. relating to this.

(7) Provide all documents (as defined on page 2, item 3, of this pleading) which substantiates that each method has been/is being trended.

(8) How many documents have been generated over the life of 36

r the plant for each such method?

(9) How many items are still open at the present time of documents generated for each such method?

(10) Include the various punch lists in your responses to items 1 through 9 preceding.

26. Provide for inspection and copying all invoices or other documentation of purchase for all pencil grinders which were purchased for use during the time Henry Stiner and Darlene Stiner worked as welders at Comanche Peak. Divide all such documents into time periods during which the pencil grinders would have been used.

27. Provide for inspection and copying all procedures, instructions, or other documents (as defined on page 2, item 3, of this pleading) which state that all welders shall have pencil grinders and/or that all welders shall have preheat bottles. Provide the original and all revisions of each such document.

28. Are NCR's currently being kept with the package of each support, etc.?

29. a. Who pays the ANI's?

b. Provide for inspection and copying all documents (as defined on page 2, item 3, of this pleading) pertaining to the work done by the ANI's, who they shall report to, who pays them, who has the authority to hire and fire them, limitation of their scope of work, etc., including but not limited to all contracts, agreements, or other related documents.

30. a. Isn't it a fact that Brown & Root's ASME N-stamp is due to expire on 3/15/85? If not, when is the expiration date?

b. Does ASME usually require a reinspection, resurvey, or audit before renewing an N-stamp?

37

'T; 1

~-

g-.. .. ,

c. . Has ASME contacted Applicants or their employees (as defined on I pages 1 and 2, item 2, of this pleading) regarding such a reinspection, resurvey, or audit?

d. .Has Brown & Root, Applicants, or any other employee of Applicants contacted ASME regarding the renewal of the N-stamp, a reinspection, a resurvey, or an audit?

e. Supply all documents (as defined on page 2, item 3, of this

~

. pleading) regarding items a. through d. preceding.

f. Has ASME made any reinspections, resurveys, or audits since the

.one which was made just prior to the last renewal of Brown &

Root's.N-stamp?

-g.- If the answer to f. is yes, supply all documents (as defined on page 2, item 3, of this pleading) regarding each such reinspection, resurvey, or audit.

31. Applicants were supposed to have been sending the Licensing Board and parties a regular update of the items to be completed in preparation f.or fuel load and Applicants' current estimate of the date of fuel load,

a. What was the. rationale or reason for Applicants' having discontinued sending the Licensing Board this information?

b. Provide all documents (as defined on page 2, item 3, of this pleading) related to this matter.

c. Provide Applicants' current estimate of the date of fuel load for Unit 1 and for Unit 2.

d. Provide Applicants' current estimate of the percentage of completeness for*each unit of Comanche Peak.

e. Provide a summary (similst to what Applicants have provide to the Board in the past) of the state of readiness for fuel 38

p: , 1 p c,..e.

I t

i i

load of each item in the plant.

32.-. a. Following the public statements made by Nancy Williams, Cygna -

, . wx .

. g 4,, W w ea Project Manager (see 2/21/85 DALLAS MORNING NEWS grticle, attached j n . .  : ,9 to' CASE's 2/25/85 Notification of New and Significant Information and CASE's Supplement to CASE's 10/15/84 Motions and Answer to

_, Applicants' Motion for Summary Disposition Regarding Stability of Pipe Supports), did anyonsb with Applicants, their, counsel, or their employees (as defined on pages 1 and 2, item 2, of this pleading) contact Ms. Williams (either directly or indirectly, .

such as through Cygna's attorney or Ms. Williams' superiors),

Cygna's counsel, or any other employee of Cygna regarding Ms.

Williams' statements and/or Cygna's position on.the stability ~

l issue? i  ;

I m o? .._

b. If the answer to a. preceding is yes, provide a summary of such - .

conversation (s) or contact (s), and all. documents (as defined on page 2, item 3, of this pleading) relating to such conversation (s) ,

or contact (s). . . . u.

.. ..#.~ m .w ,,.a.m. a.#._,.s.mc. L _ m . m,m _.% , .

~ -

"33. ' Provide CASE with Applicants' responses to each and every question -

asked informally (or formally) by the NRC Staff under the Board's 12/18/84 Memorandum (Reopening Discovery; Misleading Statement).

Provide any additional or supplementary responses to CASE at the same time you provide them to the Staff.

34. Provide CASE with all information provided by Applicants to the NRC Contention 5 Panel. Provide any additional or supplementary r'esponses to CASE at the same time you provide them to the Contention 5 Panel.

-35. In CASE's 2/4/85 Second Set of Interrogatories to Applicants and Requests to Produce re: Credibility, page 6, question 3(c) asks:

39 -

f~

" 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." .j

[;?m-

. .tn A W 1. ;2 .

m 4 . J . L. .f. M~ .e, L a. In the attached 2/21/85 FORT WORTH STAR-TELEGRAM article,-it }'

w. .

is stated:

"The utility has paid Cygna $3 million since 1983 to conduct an independent assessment of plant design safety, a company spokesman said."

w . . ~ . , - - ~ . < ..w.- ..n .m - < . , _ , . . - . -

w . ,

(1) Is the $3 million. figure stated in the article correct?

(ii) Provide all contracts, letters of understanding, or any other correspondence or documents (as defined on page 2, item 3, of this pleading) to or from Cygna regarding any amounts paid or to be paid (whether a set figure is specified or not) to Cygna by Applicants.

36. The attached 2/20/85 articles from the DALLAS TIMES HERALD, THE DALLAS MORNING NEWS, and THE FORT WORTH STAR-TELEGRAM indicate that

. Applicants' witnesses David Chapman and Antonio Vega have been diun+ymmGw%ns.,nmwwwna;;r .w,awwuweuw.wwd.wa.ws;+wa.: ,wL,,,.  ;,, ,

we e greassigned and will no longer be at Comanche Peak. . ~ + c. ~ e< r +

am

, a, / ~ : aw.u. 2, .

The articles also indicate that Messrs. James R. Wells, Phillip e

Halstead, and David McAfee will be replacing Messrs. Chapman and Vega at Comanche Peak, but that these three newcomers will not be permanent

~ ce - - -

u, r 1 employees. . _ .o - <

i.

s. Please comment on the accuracy of the preceding comments, and provide complete and specific details regarding these changes in personnel.

[ h .. _. a.r .m ,,b. .What was the reason for these changes? _ .

c. Provide the job resumes for Messrs. Wells, Halstead,- and k., * .Le *h w k w s-NsN' t na's 1 O g J 4 l ,, ,r a, y , v s .., ; , .,,,; ,, s

%.1: { u a _ "J% ajs ._ _ g: _, j,,y . . _ ,

I,... .

McAfee.

d. How long is each of these three individuals expected to

,remai n in his new position at Comanche' Pea ? .

, p , [

e. For each of these three indiyiduals, provide copies of all , a documents (as defined on page 2, item 3, of this pleading),

L, -

including all contracts, letters of understanding, or other s 1

- + - instructions to or from these three individuals from Applicants or their employees (as defined on pages 1 and 2, item 2, of this pleading) as to the scope, criteria, protocol, independence, salary and benefits, term of contract, and any other relevant data regarding each individual's review and activities at Comanche Peak.

f. Was there ever (or will there be) any kind of understanding -

(written or oral) to the effect that any or all of these three individuals is 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 ,

i a.u z, ms.. w.m.Jr. Brandt',s,af fidavit) . up;,ugg,.

,,,; ..%,wu;amm,.aa , t n .

. , p. v .wsay w x.mn.wg.? - v. .. w w . ., m, ; .

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g. If the answer to f. preceding is yes, provide all documents  ; ,

t (as defined in item 3, page 2, of this plesding) including t

contracts, relating to such understanding.,,

If no documents exist, supply specific details of such ,

- , n.. n .- ., .- . . =u. , , , -

understanding,"the name(s) (and organization and title) of each, person with whom any of the three individuals discussed such understanding, a brief summary of all discussions, the date of each such discussion, and any other pertinent

- . - - . . , , . .~ ~-,.-..n. . . . . . - . - . - .

, . . . . details. Provide specific detailed information.

h. Provide s.

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(1) a listing of all public documents (including pleadings, Proposed Findings, etc., filed by CASE) which have been

,- .? .

. ,j 9 ,_

, j provided to each of the three individuals (by,Applic, ants. g-or others); ,

l (2) a listing of all other documents (as defined on page 2, item 3, of this pleading) which have been provided to each of the three individuals; * -w (3) all documents (such as cover letters, memoranda, etc.)

by which such documents were provided; (4) if the documents were handed to the individuals on site, please so indicate; (5) who (name, organization, and title) provided each such document to each of the three individuals; (6) the date on which each such document was supplied to each of the three individuals; and (7) copies of all documents listed in (2) preceding.

i. With further reference to d. preceding, CASE is concerned w u w o a - r_.4. m .,that,these individuals.,whom,we assume. Applicants, consider..to u .

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m nn , m.y w , + . n u,, ,, .. . , nw ,e ,, a#b

^

, / be experts in quality aspurance/ quality control, will be -

leaving just at the time Applicants will need expertise in .

implementing its OA/QC program for operations.

Please provide specific details and all documentation regardingk[wApplicantsplantodealwiththispotential problem.

37. Please review all of CASE's previous interrogatories and requests to produce, and supplement your answers as necessary to comply with 10 CFR a , s.. 2 . . . . w.w: -s .. . . - , . . . . - ,

2.740(e). (When you are ready to do this, please call Juanita Ellis; we can probably assist in cutting down the scope of this request at .

fo ,

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that time.)

38. ,With regard to the Licensing Board's 12/18/84 Memorandum (Reopening ,, . . . g

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q' . + fsti~' ' L,,; it% ~Q>

- e

-Discovery;~ Misleading Statement): ' ,

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a. On page 9, the Bogrd stated:

"We also invite Applicants to review their own testimony and to disclose all their errors in the course of this proceeding (or the related docket) in a single filing, together with y a. . . u-a 2 ..,.u.w a.; explanations." ~ ~ ' , ' ' " * '" '

.,- - . y.z .o . . , . . ,

Do Applicants plan to take the Board up on its offer?

b. If the answer to a. preceding is yes, what is the time frame Applicants anticipate this will be done?

c. Please supply responses to the concerns detailed by the Licensing Board in its Order.

39. a. Provide the basis for Mr. Brandt's 9/28/84 Affidavit indicating that there are no problems with the protective coatings. Supply complete details, including all documents (as defined on page 2, item 3, of this pleading) on which Mr. Brandt relied in any way in reaching his conclusions.

. . x. . , .+ . w ,, n. . . . .

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wdw aw AO.4.Providaaba 4following..individuala e .for depositions t . msw.w.mww.mue. A ,

r,pf g u e n % v n e .p m g a g n e w e w . #.. w en.sym.m. ( . % . e.m . u , s -. ~ wa vn w., a M1 S .  % C.;C.' Randall . ,

s i

John Merritt .

41. CASE would like to set up some onsite discovery time to look at some ,

'specif'ic items (primarily, but not totally, documentation, to check out

.e. --

';. , ~ . .. a ,. , ; <,, w. - , _ . - ,,, ,

'

• the retrie'vability of documents, etc.). " * " ' '

42. Provide the basis for each of Applicants' affidavits on which the Board relied to close out items, as listed in the Board's 3/15/84 Memorandum (Clarification of Open Issues). Provide all documents (as defined on

-a ._ .a:n

• s.&m. c.: w s.m.c. s........,# _ - . - . . , ,  ; - . - . , . . . . - . . ,

page 2, item 3, of this pleading) on which each affiant relied in any way; please identify each item as to which Affidavit it applies to. *

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es Nt ) 'r 's $ %e b ',Q h-d es i eh 23 {se v ,L e< [ s e .a. < or one 'a n s. Ms s '.,s. . as n. ,, p< e ., g s p_ h L -4 4 , . _ . .i 4 j c' lpi < s 4 d 4 MhI h

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, ef $19 e i 373 7 9$ I

- $3 m v., . . r . 7 ,4 O ,;i.r '.. : , J W [e. R % j

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s

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It should be noted that CASE believes that all documents discussed _ ,

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$s herein which pertain in any way to the Walsh/Doyle allegations or , .

LUi Applicants' Plan to resolve the design / design OA concerns should be provided *:

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'by Applicants at no charge to CASE. 'It was CASE's understanding at the time' we agreed to Applicants' proposals in this regard that we would be provided with three copies (one for Mr. Walsh, one for Mr. Doyle, and one for CASE) of each such document.

Regarding the rest of the documents we have requested, CASE believes that 7 cents a page is a reasonable price to pay for them, and we are , , . . . , , . ,,

'willing to agree to that figure.

Although we have not indicated it specifically for each ites requested, we mean for all documents to be supplied for inspection and copying.

If Applicants do not agree with CASE's proposals regarding the charges '

' ' ' ~~~ '

for copying, please promptly advise so that we can'make whatever -

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%s...,m . arrangements are necessary in advance of. reviewing the. documents. e.. v m :,q.n c e ys,

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Respectfully submitted,

/D . . N ~ fN '. , '

s.) Juanita Ellis, President

.- ,. SE (Citizens Association for "~ Sound .

Energy) l '

1 1426 S. Polk e -

Dallas, Texas 75224 214/946-9446 '

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Quality [ control officials

[ replaced at Coma, n, c.ae g y%, . , , ,f., - '- -

,'ByiJACK BOCyni , r Ramsey said th4 sh.g,,

stMnmrd from last snonois t *

'(- M (S.taff..Wrtter .

l4p*^h* '

J,Dw prinripal owners of the c en g whuh the U.S. Nurlear Neaula.

8"'y Cmumanion staff said Texas

'manttw Feak nuriear plant an- "I"

"larkaus the comtrutment

• ten .

imumwd Tuesday they ar, ,,p g,,,, to aggr- '

1 IMhve ,cesively amplement an ef.

f ing'the top twe quaHey cuntrol i .'

quahty control prog % .;

.mpnagne because of federal niH. The repurt cited serious, wid *' *

e6sm about the ple1g , e.g,gy ogscail quahty g,ntrol prohkm,,s $e i

Pmeram die piani near cien Ro,,, ,

. ..Tesu unhnes Eleci,.e en "w Isra of awe reart. is w,tuai gspokesman Dck Ramary sasd the ly muplehsl. Another NRC repc

',8

g'" .

.uuhty as bringmg in thru ,9,,, snud die preekreis cw % , e

'from outsade companies, includmg ""' salestuary and quahty of s,.n. '

,the fatener head of queaty contral stsnabuss" at the plant iI

'for Duke Power Co.. widely TeP NRC efficials said last C '

ev6ewed in the industry as having m nth they beleved management .

new of the most suctiesful sycleer changen wouki be needed a w I programs in the enuntry '

'a -

5 8ee CtulANCHP: en Pere le j'y'4 13

+s: ,

/ a.4 "m..v C~o~manche Peak _

f.! s quah.ty managers C.

jh

~

to be replaced 00MANCIIE - Freas Page one assurance while lialstead will furt the situnuon. , serve as quality managn at the l l ).

g g Ik -

' You have to look at why it plant and McAfee will direct quaf" didn't work, and you have to fix say amrance at the Dallas offace, t '[fif.h d..,**

that from a corporate manage. N8'nery said Texas Utilities is esi) N4 l' ment standpoint" NRC Ikenning suH studying tte issues raised by I

4 director Darrell Eisenhut said, an NRC task force last month. ,

• l ' t .*,

Otherwise you will not have con. The utihty is scheduled to meet

[I *fidence,in this utility in the with die tank fortv for three da)s t ( i i future '* in each of the next two weeks to Whale not admitting that the discuns what needs to be done to -

plant's quahty effort has been in, remlve the NRCs quesuons. P?

adequate. Ramsey said the cunn. '!he NRC issues, which must be l pany beheved a mapr change ws, answered before the plant can re-norussary to resolve the NRCs e an r.perating Ikense, forwd

• i concerns. the uuhay on Jan. 23 to revise the '

.. 'sWe feel the restructunng will plant's ciwt estimate to $4 56 in'.

give ses a fresh approach, as well tw., abnost six umes the ongma' ULa.

as addstional management," he estamate of $779 milhort.

said. The utihty sand it now cugwu {, y ,,

~

I#'

, .The cipnges involve Davut N the farnt of the two reactors to tr. j Osapman, the quahty assuram, sin nperatusi in early 1986, sia .

y"*'8 I" hind schedule. But Pa w '

gmanager for the last eight years, * * * ' ' .

• , ',and Tony Vega.'who has sezved sey said both the cost

• and Jg .

(i

• !sincesnanager last andspring has been aspart quahty control schedule of the innspection or signifacant could change if.a,{mapr' rework f

.. uality program since construcuan is needed to ' answer the..NRQ; '

Il years agot Both wiu be questanis. -)- ..et . g g,

' *,' March . I to-posithwa ( A Washington.;DC.. based. puts .

. outai j

" opergians. . the}sosylany's

s. . t > ,nuclepr

", ' he Attuuntritmhty interest gicup, Prn)sctihas theaskedGovernment a'

• Ramgry said they  ?

placed f by}amesWella, R[will whoNtwtensing re *the BoardU.S. to croet Atomic a ecenplete Jefety and t i. .

?

,. !i*JPower's sysahty control supervi. rule on Ihe sequest, developed e- and' min' aged'

, g 'g Duk, ' reinspntion, 'D

. . lalanst severt puclear projwts in ,

1.iNorth Carolina.*and Philhp Ital- ~

s.

 ? ' '

f P'

. a Jelsed and Dav6d M. McAfee, qual. ' .'"* *

./ Ity entrol offacials.o( the.Daniels . , ', J ' . h.

9ucuori' Co

• 4 ' nuclear con. '' V. *'* ,

. treeter in Greenvtue. 6 c."' 1 .

. Q. p Remey said' ttw c-% will'b . .'" " , * ' " '

- .on loan from theil todnpanies to,

,,'yTexas Utiliths for the duration of .

' .the pre)ct. Wells will assume a..

" 4.3

.g J*

, ,8IM position as diregtor of quahty - ,

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wednesday, February 20, 1985 'en. E a M - ' ' - @ )g D I12,4 % Tgig g % $ .. . -43 ".19 A Nevu.......,.... managers hired for Comanche Peak .

By David Real med quattty contros programs to and in the quahry and the safety of ards savolving maclear< elated be the head of the newly created quauty control manager.Vega wm ast! Womeraf The as=e . guarasseethesafetyof theplant . that piar.t and ta car abahty to quahty assurance =5- --- - per. - of!1ce of director of quahty assur- become manager of-the systems, la a mager shakeup of the tropy , thka Spence, prmlant of Texas 6dennfy and solve our own prob. formed by Brown & Root Inc. of ance and ws!! report directly to protection and testing divtston for

~

Houston, the grneral contractor Bally Clements, vice prestdent of Da!!as Power & Light Cow -

bied quahty assurance program at Unhtnes Generaung Ca. said the

• less-- ,

e David McAfee,also of Daniels en-awa. peak awlane power , h of the new personnet and

• Vlace Noonan, the NItc project for Ca==acha Peak. Spence would , nuclear operanons. Spence said.

plant, Texas Ut18ttee will hare the creattan'of a new office for ' manager for Osmanche Peak and ' not comment directly on Brown & Wells has almost 20 years expert- ' Construcuos is years Co h8cAfee,who of experience an gaahty has three managers with extenstve no- quakty assurance was destgned to director of the special NRC task . Root but said correcure acnons encein quahtyasrarance.

a Philhp Halstead of Daniels assarance, including 10 years as a clear experience, unhty ofMale 'promoes a fresh management per- force that idenufnes quahry assur. willbedeveloped asrequired.".

specave requened by the NRCJan. ance problems at the plant,said he : Spence sud the new managers. Constracnoa Ca. -of Greenville. quautyassurance manager,willre-

, saat. .

. The Necteer Segalaeury Com.'- 8. - --

generallyapprovedof thechanges ..who carrently work for highly re. SC. Halstand, who has more than place David Chapman as the Dal-z!anos last ==mcrtuctaed sen- Spence said the changes were -Ira a saep in the right direc. _ garded companies that have but! 14 years of heavy construction ex , lasbased manager of quahty assur-

% settley asnegmuseet Ser lack af **m,adr an "matassia and to the ex

• tion *Mooses seed *** **N + almest a denen maclear plaats are:_- pensace and esperuse in nuclear a ence.: char === - will. assist the .

- 5JamesR.Wellsof Dukapower inspecnon, will replace Antense i,Texaistuhtaas GeneratingCd.tice f==hetoeggrenstratyleapis *-seat

• ragstradi regata,the comin ,,- ButLasmedthathestillhadcoa. . *

,d- ment

.,_-a e5ective quahty .asurance,' demos -

of the.1eC la se.r progra.sa_. .corns. ahost poematial safety has t-Cirof_Marth

.. -- CarottaaL-Wells

- - wtII: ~ ua.Ve.ga..as._the Com.anche., peak sise , presid

, 7 __ _

4 *..

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l hany&M Nroldu$epiahhc{citN'wh@y'k j

t FORT WORTH STAR-TELEGRAM $

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• T

$ NuclearRegulatoryCommissionsaidTexc . top quality centrol manager Dave Cha nuclear reactors whGefat Duke Power 6 b

f ~ By BRUCEMfLLAR $ Assisting Wells will hiitwo ex perienced *

'

• sin Teksrem w,u'* .1.as Utilities Electric Co. had not demon

• man and hisonettedeputy, AntonioVega,

~

will be transferred laterally to non-nuclee engineers now employbd by Daniels Con-

,; Inthesecondman$gementshuffleinat - stratedacommitmenttoaggressivequali - t struction Co. of Greenville. S.C.The firm l many weeks. Texas Utihties Electric Co,. ty control Chapman.han in several and key hgnded;the areas.for".wnTuesdayremoved program las,been has been a',contrJacth at

,: w . .9 .:f.our

controlmanagersandreplaced themwitht more than 100 potential safety concerns ,7 more thaa.  ;

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dasoplarcivilengineet e

ithree outside specialists whohave had nc with the quality control program. Utility , ; staunch ^ *(plant's PhillipHa p.c., day r control .with .14 years',ex jaheavy, pen-Involvement at the troubled Osmanchei officials next month are espected to1 ? unveil Peak nuclear power plant.f .

ies-R. Wells, taruction their wS plan foresremedying t

'** for North, oFqaalag s -

yCompanyspokassaanDickRamseysaid-* problems.' n ~ ~? "'.~7 s V'

• h , < rector et 7 f ^ ~ber:Eo .will~ a===m the management shaktarp was needed tgp*It is our conclusion that this is the sort ~ c.rolinaY Duiseli. Atee,whohasisygundM newly created pastetah me di 4

! add a"freshperspective"andextrasenior s of thing that it is going toJ take to resolve ' ity assurance. HeihSaupervise experience,@G8pg,$

aboug q

' g*,Pleasegg, gage, t j { management supervision to the utilityW the concerns" Ramsey said.Q bqualitycontrolg,L i

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~

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n, 9 Qu;r.:ah.tym, ,; control duo repl ar.geds .. -pla,nte' l

l . g ft M 4 ta-

' w Continged [Ws L t Rf e 1[ I N.

t v .1 [*$$ 2 ; k Last March,e plant buut by Duke Power kNessingofISLEe

%LN "" .

batawbaplantin ' tb $

y2 i f' sean * '

M /' ~5

{  ! "We think we are pretty fortunate to get peo commercial operations at one third the rolikM l lple of thell'eallber,* Ramsey said.l the average new U.S. nuclear plant ' % '

Theyhaveaverysuccessfulnuclear

' Carde sab solvingcomp MnN"ffectl[t hweldingquality' I

I I The utility must demonstsete an effective '

,;quality control program to obtain a federal oper- and thisis theguywhodeveloped and - ==;str, at the@*a.be nuclear power

, ating license. Two weeks ash, utility officials - theirquall

~

program." ram ' phatwast? .e month)uta s +

T f announcedanotherattempttobolsterNRCcon , Critics of r*a=an% Peak & u ~+5 -

N. -

'4 - . i' (idence la the utility's ability tecorrect problems unimp at the $488 biDios plant.'the giant is near Glen "I the

.ySw , & 3,.

adaMthat t

'Rakk' were la rs of Cha es.LVega. who.has n$

L Rose,4Alles west of Worth. : assurancel islashambles,"said ' Texas ,, uclear prograss ferd11, i panel Feb.7 that. Ellis,y the Dalkbened Citiases years,will b,ec- - ager of the systems pro-

.. . .aa been replaced on clation for senad Energy.; < - W' and R ^~-^ -for -

> a

.,two top anscutives ni r Q

, the (g. m.a. 6 actiegleam by outside- :"Theymee(derethanfresh ELight. W% a ^E;.g T

! experts /nneehangeswouldunakeQieteammore need a change-of attitudeirom ugpet Cha ' awGi s'esistanttoM <

Co. vive for' '

independentimdobjective,isWityofficialssaid.1 meat on dova,through the ranks, Ramessy Wells ._f- ning and op' > Billie Gardsta te$neentativs of the tilitig topera C s h543t3 & .'

erating' Power's quawassurance pro ~ meat AccougsbuityProject basedla .Ramesey said the thfee newco$i rs would not-. #

gram.DukePowerboastsoneafIhemostsuccesst ton,D.C.,ertticised theappointmente(W permandat He said they'wng)d he' j fulconstrue.tlonrecordsInthenuclearindustry ; " extremely unfortunate.*'. GAP had o !pa loan. .Mc .

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'. y.- . NUC. LEAR REGULATORY

, COMMISSION .

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the~ Master'of }{ ,

e - }{ .-

TEXAS, UTILITIES.. ELECTRIC a . w w }( c u Docket Nos. . 50-445-1 .x mm

-COMPANY, _et- al. % x - '

}{ and 50-446-1 < + +4 (Comanche Peak Steam Electric }{ -

Station, Units 1 and 2) }{

CERTIFICATE OF SERVICE By iny signature below, I hereby certify that true and correct copies of CASE's Fourth Set of Interrogatories to Applicants and Requests to Produce

~

re: Credibility

~ ~ '

have been sent to the names listed below this 25th day of ' ~ February ~,198 5,""'

~

by: Express Mail where indicated by

• and First Class Mail elsewhere. ,

• Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq. -

U. S. Nuclear Regulatory. Commission Bishop, Liberman, Cook, Purcell

- .44350 East /Westlighway, 4th Floor ... .. J.& Reynolds ~ ~.

m. - . ,4 sa.y ;- l

~Bethesda Maryland 20814' . . . 1200 - 17th St., N. W.

94& hAK4%.m m p, 'wppla.;e gem c ytrgw% shHg t o'n',' D 2 C .* 20036D W I M bN*h

)Ma wgT,%g/ MMM$3'7%hiis6n%@WMW E

~'

• @**fMP@" N#Wf""" W+# * ' ' ' ~~~ '

~ " Oak ~RidgA National' Laboratory '* Ceary S. Mizuno,"Esq. '

i P. O. Box X, Building 3500 Office of Executive Legal 10ak Ridge, Tannessee 37830 Director. -

U. S. Nuclear Regulatory j

• Dr. Kenneth A. McCollom,~ Dean' Commission - ' - '

, Division of Eng6neering, . Maryland National Bank Bldg.

~ Architect _ure and,Techn.. ology - Room 10105 - .

v < n0klahom_a., State q . Eniversity m m #

- . _ . _ . . _ ,.m.,

n.7735 Old Georgetown Road y .

4 m #

!~

.Stillwater,' Oklahoma ' 74074 Bethesda, Maryland '20814 ,

• Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing L

l 881 W. Outer Drive Board Panel

' Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission 20555

~

Washington, D. C.

+,nnyem,. . ,nn.

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Chairman Renea Hicks, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General

, Board Panel. ,;. , ..

. Environmental Protection' Division;'-$l ".d ~7 Supreme Court Building ~ W M$ Y~[y." .

. . . ~

~

' U." S.' Nuclear Regulatory Commission "

Washington,' D. C. 20555 Aus, tin, Texas 78711 . .ag: ,; ,,,;, , . s, Mr. Robert Martin Anthony Z. Roisman, Esq.

• Regional Administrator, Region IV Trial Lawyers for Public Justice ,

U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C 20036 -

Arlington, Texas 76011 '

es -n.

Mr. Owen S. Merrill -

Lanny A. Sinkin Staff Engineer 3022 Porter St., N. W., #304 Advisory Committee for Reactor Washington, D. C. 20008 bafeguards (MS H-1016)

U. S. Suclear Regulatory Commission Washington, D. C. 20555 Dr. David H. Boltz 2012 S. Polk.

~ ' '

Dallas, Texas 7522' Michael D. Spence, President .

Texas Utilities Generating Company Skyway Tower . - s. w . -

400 North Olive St., L.B. 81 Dallas, Texas 75201  :. C .a ,. ;, r..r.

Docketing and Service Section ' ' " "

(3 copies) _

a sp a r- .0ff, ice,,of the,Jee,ratary, g,m, _.,,

.. ,m.,u 4,,m.g w gbgwn4y U.'S., Nuclear Regulatory , Commission ,, . ,, ,,,g , g ,, .% gpu , .g p

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w w.agn.4 t, Washington, D. C. -20555 , _ .

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u,

' s.) Juanita Ellis, President .

ASE (Citizens Association for Sound Energy) 1426 S. Polk ,

Dallas, Texas 75224 l 214/946-9446 u - . - -  :- ,

. . - = - . .- . - -

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