ML19346A043
| ML19346A043 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/22/1981 |
| From: | Gay G, Jordan W CITIZENS FOR EQUITABLE UTILITIES, GAY, G.M., HARMON & WEISS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8106040441 | |
| Download: ML19346A043 (2) | |
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UNITED STATES OF AMERICA NUCLEAR REGUIATCRY CCMMISSION g
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cogge W-C8 In the Matter of HCUSTON LICHTING & FCWER
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Docket Nos. 50-498 OL CCMPANY 50-499
- 977-(South Texas Project, Units 1 & 2)
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- CITIZENS FTR EGUITA3IS UTILITIES e
y.cco MOTION TO CALL ADDITICNAL WITNESS AND M0"' ION
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FCM F*0 TIC"'IVE CMDEM
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Pursuant t'o 10 CFR 2.743 and 2.711(a), CEU moves that it te permittrd to call an additional witness. This witness contacted CEU en Thursday, April 30, 1981. CEU immediately arranged for a contact totween the individual and the NRC Staff, and we understand that an N3C investigation is new underway. The individual approached CEU in confidence and continues to seek protection of identity. In this Motion, we set out good cause for callin6 this witness to the extent possible without providing identifying information. We will provide protective order if the Staff indicates i
further information under a that the individual's icentity need not he protected from Applicant's counsel.
l This individual has werked at the South Texas Project and has int l
formation concerning conditions and management attitudes at the Project, l
toth prior to the Show Cause Order and since the Order. The individual's information relates specifically to attitudes toward and treatment of Quality Assurance / Quality Centrol personnel, attitudes toward tuality Y 6r in general, and other =atters. In particular, this individual has i D l
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information of vital importance to this record on Contentions 1 and 2 and l
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a d on the fundamental issue of character and competence, as defined by the Commission.
The moet significant fact concerning this individual's information is that much of it relates to the period following the Show Cause Order.
The record is already replete with HL&P descriptions of organi::ational chan6es and promises of improved performance, However, it is and promises
's rer.ain virtually devoid of any solid evidence of actual conditions at the project. The information available from this individual can cese from no other source, but it gets to the very heart of the issue of whether there has teen a real char.ge at the South Texas Project, or whether what we have heard is primarily cosmetic.
Respectfully submitted, f,,
9%)w William S. Jordan, III Harmon & Weiss 1725 I S t., N.W.
Suite 506 Washington, D.C.
20006
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Geoffrey M. Cay 3245 S. University Dr.
Fort Worth, Texas 76109 Counsel for CEU Dated: May 22, 1981 Note: Service will be made on HL&P, the NRC Staff, CCANP, and the Licensing Board by hand on Friday, May 22, 1981, during the heariag. The remaining repuired service will be accomplished by mail en Monday, May 25, 1981.
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