ML19331B920

Response to Citizens Association for Sound Energy 800707 Requests for Production of Documents Re First Set of Interrogatories.Makes Available Certain Matls.Remaining Matl Will Be Produced After Clarification.W/Certificate of Svc

ML19331B920
Person / Time
Site:	Comanche Peak
Issue date:	08/11/1980
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8008130533
Download: ML19331B920 (6)

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Augusg- ly 1980 UNITED STATES OF AMERICA # k;g NUCLEAR REGULATORY COMMISSION #g 0 ,

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.,k BEFORE THE ATOMIC SAFETY AND LICENSING EQARD

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In the Matter of ) s ,

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COV?ANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

APPLICANTS' RESPONSE TO CASE'S REQUESTS FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. 52. 7 41 (d) , Texas Utilities Generating Company, et al., (" Applicants") hereby submit Applicants' response to CASE's requests for production of documents set forth in " CASE's First Set of Interrogatories to Applicant," dated July 7, 1980. Applicants also set forth below procedures for inspection and copying of the documents requested by CASE.

Applicants' Responses to Requests to Produce Each request to produce is identified by item number, corresponding to the numbers in " CASE's First Set of Inter-r'ogatories to Applicant," dated July 7, 1980.

Contention' 5 Question: -

1. Supply copies of each and every Deficiency and Disposition Report (DDR) log.

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2. Supply copies of each and every Non-Conformance Report (NCR) log.

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4. Supply copies of each and every Corrective Action l Request (CAR) log.

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11. Regarding items 8 through 10, provide the following information: j i

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(d) Where is the audit, evaluation, or study kept so that we can review it?

[Regarding Item 8]

14. If the answer to item 12 is yes, supply copies of all publications or information by all such depart-

ments regarding the quality control, quality assurance, safety, workmanship, and method by which the plant is being built.

18. Supply copies of any~and all progress reports to the public regarding CPSES, includin'; information provided at the CPSES information center.

19. Supply copies of all quality control manuals, folders, pamphlets, and any other printed informa-tion regarding quality control, including procedures for quality control, not only current but the originals and all revisions.

21. If ths answer to item 20 is yes, where are such tapes kept so that we can review them?

22. Supply copies of all quality control specifications manuals, folders, pamphlets, and any other printed information regarding quality control specifications, not only current but the originals and all revisions.

23. Supply copies of all manuals, folders, pamphlets, and any other printed information regarding quality assurance specifications, and quality assurance pro-cedures, not only current but the originals and all revisions. If this information has been supplied in response to item 19, so state.

Answer:

Applicants will produce for inspection and copying the documents identified above according to the following pro-cedures:

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1. The documents identified above will be provided for inspection at the Texas Utilities Generating Company offices, 18th Floor, 2001 Bryan Tower, Dallas, Texas, during normal business hours (8 a.m. - 5 p.m., Monday - Friday).

2. CASE should schedule inspection of documents by notifying Homer C. Schmidt, at (214) 653-4782, -

who will arrange'for documents to be inspected.

3. CASE should not remove any documents from the room provided for such inspection. CASE should identify those-documents it wishes to be copied and Applicants will make and supply copies at CASE's expense and at a rate of 15 cents per page.

Question:

3. Supply copies of each and every Field Request for Engineering Action (FREA) log.

5. Supply copies of each and every Concrete Pour log.

9. How many audit.s have been performed by insurers (industrial risk, builder's risk, etc.) on work done at the Comanche Peak plant?

10. How many outside or sub-contractor evaluations, studies or audits have been conducted (by sub-contractors or agents of sub-contractors or by consulting firms or others, etc.) ?

11. Regarding items 8 through 10, provide the following information:

(d) Where is the audit, evaluation, or study kept so that we can review it?

[Regarding Items 9 and 10]

Answer:

Applicants will respond to these requests to produce as clarified by CASE pursuant to Applicants' requests for clarification in Applicants' Answer of July 28, 1980. ,,

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I Applicants received CASE's response to Applicants' requests for clarification on August 7, 1980. Applicants are examin-ing CASE's response and will respond to it shortly.

Respect ul submitted, f

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Nichol S/.1 Reynolds V

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William A. Horin~

Debevoise & Liberman 1200 f.eventeenth Street, N.W.

Washington., D.C. 20036 (202) 857-9817 Counsel for Applicants August 11, 1980 t

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

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al.-~

) 50-446

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(Comenche Peak Steam Electric ) (Application for -

Station, Units 1 and 2) ) Operating License)'

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Response To CASE's Requests For Production Of Documents,"

in the captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this lith day of August, 1980:

Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman,' Atomic Safety and Licensing Board Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Chairman, Atomic Safety Elizabeth S. Bowers, Esq. and Licensing Appeal Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washingten, D.C. 20555 Commission Washington, D.C. 20555 Marjorie Ulman Rothschild, Esq.

Office of the Executive Dr. Forrest J. Remick, Member Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission 305 E. Hamilton Avenue Washington, D.C. 20555 State College, Pennsylvania 16801 David J. Preister, Esq.

Dr. Richard Cole, Member Assistant Attorney General Atomic Safety and Licensing Environmental Protection Board Division U.S. Nuclear Regulatory 'P.O. Box 12548 Commission Capitol Station Washington, D.C. 20555 Austin, Texas 78711  ;

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Mr. Richard L. Fouke Mrs. Juanita Ellis CEUR President, CASE 1668B Cartor Drive 1426 South Polk Street Arlingt6n, Texas 76010 Dallas, Texas 75224 Arch C. McColl, III, Esq. Mr. Geoffrey M. Gay 701 Commerce Street West Texas Legal Services Suite 302 100 Main Street (Lawyer 5 Bldg.)

Dallas, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq. Mr. Chase R. Stephens 4021 Prescott Avenue Docketing & Service Branch Dallas, Texas 75219 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 William A. Horin

.cc: Homer C. Schmidt Spencer C.. Relyea, Esq.

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