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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20155F7031988-06-10010 June 1988 Applicant Supplemental Responses to Case Discovery Requests.* Suppls Responses to Interrogatories 31 & 32 & Interrogatory 32 .W/Certificate of Svc. Related Correspondence ML20155F6751988-06-0808 June 1988 Applicant Supplementation to Answers to Case 850827 Interrogatories to Applicant (850827).* No Further Documents Will Be Provided in Response to Interrogatories H-3 & H-6. Certificate of Svc Encl.Related Correspondence ML20148D4911988-03-22022 March 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicant (870825).* Certificate of Svc Encl.Related Correspondence ML20148D0571988-01-22022 January 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicants (850827).* W/Certificate of Svc.Related Correspondence ML20236X2161987-12-0404 December 1987 Permittees Supplemental Response to Meddie Gregory Interrogatories & Request for Documents (Set 5).* Response to 870409 Interrogatories Re Seismic Design of Control Room Ceiling.Certificate of Svc Encl.Related Correspondence ML20236X3191987-12-0404 December 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant 850827.* Related Correspondence.Certificate of Svc Encl ML20236X3301987-12-0404 December 1987 Supplemental Response to Intervenors Document Production Request Dtd 870619.* Related Correspondence.Certificate of Svc Encl ML20235W1931987-10-0707 October 1987 Supplemental Response to Intervenors Document Production Requests.* Applicants Will Make Listed Matls Available to Intervenors Representatives for Exam & Copying in Dallas,Tx Ofcs.W/Certificate of Svc.Related Correspondence ML20235F2521987-09-22022 September 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Organization Charts Available for Review.Resumes Will Be Obtained Upon Request. W/Certificate of Svc.Related Correspondence ML20237L7181987-08-19019 August 1987 Supplemental Responses to Case Interrogatories Re Mac Rept & Issues Raised by Mac Rept ML20238A7531987-08-14014 August 1987 Responses to Consolidated Intervenors (870619) Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20237K1941987-08-10010 August 1987 Further Answers to Comanche Peak Review Team Interrogatories (Set 12) Re Reinsp Program for Random Errors.* Related Correspondence ML20236E8041987-07-22022 July 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20235G5011987-07-0606 July 1987 Case Supplementary Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc & Three Oversize Newspaper Articles Encl ML20215J8801987-06-19019 June 1987 Consolidated Intervnors Interrogatories & Reguest for Production of Documents to Applicant Texas Utilities Electric Co (870619).* Related Correspondence ML20215J7741987-06-19019 June 1987 Applicants Interrogatories to Intervenor (Set No. 1987-9).* Certificate of Svc Encl.Related Correspondence ML20215K2951987-06-15015 June 1987 M Gregory Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc Encl ML20214W5711987-06-0808 June 1987 Applicant Supplemental Responses to Case 860630 Interrogatories & Request for Documents.* Info Requested from Stone & Webster Submitted as Interrogatory 32.W/ Certificate of Svc.Related Correspondence ML20214W5601987-06-0606 June 1987 Case Response to Applicant Interrogatories to Consolidated Intervenors (Set 1987-1).* Case Would Object to & Moves for Protective Order Against Having to Go Into More Extensive Detail Pending Completion of Discovery ML20214P0861987-05-28028 May 1987 Further Answers to Interrogatories (Comanche Peak Response Team Sets 1-7).* Applicant Suppls Responses to Certain Interrogatories Propounded by Case,Per Board Orders Rendered on 861215.W/Certificate of Svc.Related Correspondence ML20214N1021987-05-21021 May 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Related Correspondence ML20206M4411987-04-15015 April 1987 Permittees Final Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0201987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Responds to Interrogatories Re Housekeeping & Sys Cleanliness. Certificate of Svc Encl.Related Correspondence ML20206H0941987-04-13013 April 1987 Permittees Further Responses to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0031987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205M2781987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Cables Must Be Separated from Conduits Inside Panels by Min Distance of 6 Inches.W/Certificate of Svc.Related Correspondence ML20205L8151987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205L8281987-03-28028 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-4) & Motion for Protective Order.* Applicant Discovery Conflicts W/Board Assurance That Case Will Have Sufficient Time to Analyze Data.W/Certificate of Svc ML20205R5201987-03-27027 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20204B7441987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-6) & Motion for Protective Order.* Identification of Experts Not Discoverable Due to Irrelevancy of Opinions Based on Work in Progress.Certificate of Svc Encl ML20205M1831987-03-20020 March 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Charts Available for Review. Resumes Obtained & Will Be Provided If Specifically Requested.W/Certificate of Svc.Related Correspondence ML20204B7211987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-5) & Motion for Protective Order.* Applicant Requests Premature & Unanswerable by Case Until Comanche Peak Response Team Discovery Complete.W/Certificate of Svc ML20204B6651987-03-18018 March 1987 Applicant Interrogatories to Consolidated Intervenors (Set 1987 -1).* All Instances of Alleged Applicant Intentional Conduct to Delay Const of Unit 1 Requested.Certificate of Svc Encl.Related Correspondence ML20212N5981987-03-0505 March 1987 Applicants Interrogatories to Intervenor (Set Number 1987-8).* Interrogatories Concern Application for Ol. Certificate of Svc Encl.Related Correspondence ML20212D0511987-02-26026 February 1987 Applicant Interrogatories to Intervenor (Set 1987-6).* Set of Interrogatories Re Identifying Experts Consulted W/Or Retained by Intervenor W/Respect to Problems in Facility. Related Correspondence.Certificate of Svc Encl ML20212C8581987-02-26026 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-7).* Info Re Walsh/Doyle Issues &/Or Allegations Requested. W/Certificate of Svc.Related Correspondence ML20212D1381987-02-24024 February 1987 Applicants Interrogatories to Intervenor (Set No. 1987-5).* Interrogatories Re Application for Ol.Certificate of Svc Encl.Related Correspondence ML20211F5681987-02-18018 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-4).* Certificate of Svc Encl.Related Correspondence ML20211C9641987-02-13013 February 1987 Permittees Supplemental Response (Motion for Protective Order) to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20211D0011987-02-10010 February 1987 Permittees Supplemental Responses to M Gregory Interrogatories (Set 5).* Suppls Responses to M Gregory Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20210E4481987-02-0303 February 1987 Permittees Initial Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20209B0791987-01-29029 January 1987 Applicant Interrogatories to Intervenor (Set 1987-3).* W/Certificate of Svc.Related Correspondence ML20209B0321987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20209B0581987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20212R6211987-01-27027 January 1987 Supplemental Staff Answers to Case Interrogatories.* Suppls 861205 Answers to Case 860922 Discovery Request & Interrogatories 2,4 & 8.Affidavit & Certificate of Svc Encl. Related Correspondence ML20212K6991987-01-21021 January 1987 Applicants Supplementation to Answer to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20207Q2721987-01-16016 January 1987 M Gregory Request for Production of Documents (Set 6).* Certificate of Svc Encl.Related Correspondence ML20212E7501986-12-30030 December 1986 Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20211M8661986-12-0808 December 1986 Response to Case 860918 Eleventh Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence ML20211M8901986-12-0808 December 1986 Answers to Case 860918 Tenth Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence 1988-06-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
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1 ecm0; LAW orrsCES OF D E B EVOIS E &. Ll B ERM AN kh 8200 SCVENTCCNTH STRCCT.N.W.
WAS HINGTON, D C. 2OO36 (ji f !C . e -;. TCLCPHONC (202) M37-93OO
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May 27, 1982 Mrs. Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 Subj: Texas Utilities Generating Co.,
et al. (Comanche Peak Steam Electric Station, Units 1 and 2), Docket Nos.
50-445 and 50-446; Clarification and Supplementation of Responses to CASE's Eleventh Set of Interrogatories
Dear Mrs. Ellis:
This is to confirm the results of Applicants' telephone conversations with CASE on May 25 and 26, 1982, concerning (1) possible supplementation by CASE of its responses to Applicants' Interrogatories regarding specification of issues for litigation, and (2) CASE's requests for further information with respect to certain interrogatories posed in CASE's Eleventh Set of Interrogatories to Applicants.
As you know, we have repeatedly requested that CASE identify the specific issues involving Contention 5 that it intends to raise at the evidentiary hearings. You also recognize that CASE is under a continuing obligation to supplement its answers to Applicants' Interrogatories.
i 10 C.F.R. $ 2.740(e). To date, we have received only
' one supplementation of your answers as to the specific issues you intend to raise, and in that supplementation you specified only two issues. We inquired in our telephone h
3 8206040018 820527 /
PDR ADOCK 05000445 0 PDR
Mrs. Juanita Ellis
- May 27,,1982 Page 2 call yesterday as to whether QASE was finally able to provide specifics on Contention 5, and you advised (as you have in the past) that you were unable to do so at this time. You further advised that Applicants would be notified of specific issues when CASE files its answer to Applicants' Motion for Summary Disposition of Contention 5. Of course, CASE will not file that answer until June 2, two business days before hearings commence.
With regard to CASE's requests for supplementation and clarification of Applicants' responses to CASE's Eleventh Set of Interrogatories, */ by telephone call to Applicants' counsel on May 24, 1982, CASE sought clarification or supplementation of Applicants' answers to Interrogatories 1, 26(b), 51, 52(h), 54, 56, 63, 67 and 68, 75(a)-(e), 75(m),
85,97-100, 101-105, and 106.d.(1), and posed additional questions based on CASE's review of documents supplied to CASE.
Interrogatory 1 As Applicants indicated in our telephone conversation on May 26, CASE may supply a liat of documents which it intends to introduce for which Applicants will verify that Applicants provided true and correct copies of those documents to CASE. In addition, as Applicants indicated in our conversation, CASE should supply prior to the hearing copies of the documents CASE intends to introduce at the hearings for Applicants' inspection to enable Applicants to stipulate as to their authenticity. CASE stated that it understood Applicants' position and would try to work this out before the hearing.
- / CASE's Eleventh Set of Interrogatories was served on Friday, May 7, 1982 and received on Monday,,May 10.
Applicants' written responses to CASE's Eleventh Set were served on May 17, 1982, with hand delivery of a copy to CASE on May 18, 1982. At that time, Applicants already had made available documents located at the site which were requested in the Eleventh Set (May 14 and 17), and the documents located in Dallas which were requested in the Eleventh Set were made available that day (May 18).
Mrs. Juanita Ellis May 27, 1982 ,
P. age 3 Interrogatory 26(b) .
As Applicants stated in our May 25 telephone conversa-tion, to the extent information concerning FDR and CMC trending exists, it is set forth in a separato section in the four 1981 Corrective Action Reports which have already been provided to CASE. CASE indicated that this information satisfies its request.
Interrogatory 51 As Applicants confirmed in our May 26 telephone conver-sation, there are no documents of the type which CASE requests applicable to the particular 10 C.F.R. $ 50.55(e) item cited by CASE, except for the formal communications between the Applicants and the NRC, which documents should be in the local Public Document Room. Further, as CASE requested in that conversation, Applicants will provide copies of the SDARs and the reports listed in the logs applicable to items reported to the NRC pursuant to 10 C .F . R. $ 50.55(e).
Interrogatory 52(h)
As Applicants stated in'our May 25 telephone conversa-tion, there are no "as built" drawings completed at th.is time. Applicants noted that although our original response had not been clear on this point, we had previously discussed this matter with CASE. CASE indicated that this information satisfies its request.
Interrogatory 54 As Applicants indicated in our May 25 telephone conver-sation, while standard language may be used in those letters, no " form letter" such as one containing preprinted language exists. Applicants offered to provide a copy of the letter-head stationary to CASE if it desired. CASE indicated that it did not need to see that document.
4 Mrs. Juanita Ellis
- May R7, 1982 Page 4 Interrogatory 56 ,
Applicants noted in their May 24 telephone conversation with CASE that these documents had been supplied in the order in which they were used and that order was explained at the time the documents were provided to CASE. Thus, it should be clear as to which dates provided in Applicants' original response apply to which forms. However, Applicants again explained that order in our telephone conversation of May 25.
Interrogatory 63 As Applicants stated in our May 25 telephone conversation, there are four companies involved in this activity. Those companies are TUGCO, Brown & Root, Gibbs & Hill, and Ebasco Services, Inc. CASE indicated that this information satisfies its request.
Interrogatories 67 and 68 As Applicants indicated in our May 25 telephone conver-sation, the scope of Applicants' responses extended to TUGCO and Brown & Root notification pursuant to 10 C.F.R. Part 21.
l l
Applicants had explained this to CASE when CASE was reviewing documents supplied in response to its Eleventh Set on May
- 18. Further, as Applicants stated, notification by other organizations, such as vendors, pursuant to Part 21 is made directly to the NRC, although Applicants will also be notified of applicable Part 21 notices. Applicants do not, however, keep a separate folder on Part 21 notices. CASE indicaten that this information satisfies'its request.
i Interrogatory 75(a)-(e)
As Applicants indicated in their telephone conversation on May 26, the items referenced by CASE are use'd solely for cross-referencing purposes on the computer. The NCR form was c
revised in 1978 to delete the input data fields from the l
l face of the form. CASE stated that it was not interested in that information.
. --~
Mrs. Juanita Ellis -
May-27, 1982 Page 5 Interrogatory 75(m)
Applicants explained the meaning of these items in our telephone conversation of May 26, and indicated we would determine whether, with respect to items (20) and (22), the individuals examined the particular items prior to signing the form. Applicants hereby confirm that those individuals are not required to examine the particular items, but may do so prior to signing the form.
Interrogatories97-100 Applicants indicated in our May 26 telephone conver-sation that, as phrased, these categories were extremely broad, making it impossible to identify any individual for the areas specified. CASE indicated that it will attempt to narrow the subject matter in which it is interested.
Interrogatories 101-105 As Applicants indicated in our May 26 telephone conver-sation, much of the information requested in these interro-gatories is contained in documents already provided to CASE or which should be available in the local Public Document Room. Nonetheless, Applicants provided responses to these interrogatories, as discussed below.
In response to Interrogatory 101, Applicants stated that rock overbreak and subsequent additional excavation occurred in the excavation for Unit 1 and Unit 2 contain-ments and an area between these two excavations. This area is under the current Fuel Building and Safeguards Building.
With respect to Interrogatory 102, Applicants responded that they did not know precisely when the first verbal report was made to the NRC or to which individual that report was made.
l l
t
t .
Mrs. Juanita Ellis ,
May 27,-1982 Page 6 Applicants noted, however, that Brown & Root, Mason-Johnson Ascociates and Texas Utilities Services personnel were on site and carrying out functions associated with the excava-tion. All of those personnel had the opportunity to observe such conditions as they.were identified. With respect to the inquiries concerning prospective witnesses, Applicants indicated that in their opinion CASE's inquiry was outside the scope of Contention 5 in that it raised matters unrelated to quality assurance. Atuordingly, Applicants had not planned to call witnesses on this issue. However, if the Board determines otherwise, Applicants will offer Mr. Ken Scheppele of Gibbs & Hill, New York, and Mr. John Merritt of Texas Utilities Services to respond to questions on the subject.
With respect to Interrogatory 103, Applicants noted that occurrences of rock overbreak were reported for the excavation as a whole, and identified in terms of the specific areas in which they were observed.
Regarding Interrogatory 104, Applicants stated that l all documents pertaining to rock overbreak and subsequent l excavation or fissure repair were made available to CFUR in its discovery on Contention 7, and that those documents also had been made available to CASE.
Finally, with respect to Interrogatory 105, Applicants noted that parties are not required to undertake in response to discovery requests the burden of preparing another party's case. See Boston Edison Company (Pilgrim Nuclear Generating Station, Unit 2), LBP-75-30, 1 NRC 579, 588 (1975). Accordingly, Applicants refer CASE to FSAR { 2.5, l wherein the rock underlying the Category I Structures for Comanche Peak is discussed.
Questions Based on Brown & Root Trending Reports CASE posed several questions concerning the Brown &
Root Trending Reports which had been supplied by Applicants in response to CASE's Eleventh Set. As Applicants indicated in our May 26 telephone conversation, we will provide the l following additional documents:
I l
Mrs. Juanita Ellis ,
May 27,.1982 Pag'e 7
- a. Applicants will supply the 1982, first quarter, Brown & Root Trending Report.
- b. Applicants will provide a copy of.the Inter-office Memorandum referenced in the November 1974 Report.
- c. Applicants will provide copies of the particular portions of the logs identified in the October 1975 Report.
- d. As Applicants indicated, our copy of the FDCR Summary attached to the March 1976 Report also is missing the numbers in the margin. In that Applicants are not required to maintain such reports and do so for informational purposes only, there are no other copies available.
- e. Applicants will provide a copy of the July 1977 Report which was inadvertently not included in the reports provided to CASE. Further, the list of
" Monthly Quality Engineer Activities" is not a trending document and thus, as CASE agreed, does not fall within the scope of the interrogatory.
i f. The " manual" which was referenced in the June 1978 l Report is a collection of selected Brown & Root procedures already reviewed by CASE. Applicants provided a list of the particular procedures included in that manual in our telephone conversation. These procedures are CP-QAP-14.1, CP-QAP-15.1, CP-QAP-15.2, l CP-QAP-15.3 and CP-QAP-16.1.
- g. As for the trending charts which were included in some Brown & Root trending reports, Applicants indicated that there were no trending charts for the period January 1978 through July 1978.
l Vendor Audits CASE also requested copies of vendor audits conducted by organizations other than TUGCO. Specifically, CASE requested copies of Brown & Root vendor audits which were referenced in the Brown & Root Trending Reports supplied to CASE. On this matter, Applicants had asked CASE on May 24 to specify
Mrs. Juanita Ellis May 27, 1982 Page 8 ,
the particular interrogatory in which it had asked for such vendor audits. CASE indicated in our conversation on May 25 that it believed Interrogatories 113 and 119 of CASE's Ninth Set encompassed such a request.
As Applicants stated in our May 26 telephone conversa-tion, Applicants responded to Interrogatory 113 as applying to material within the scope of Mr. Lobbin's review of Applicants' OA program. In this regard, Applicants referred CASE to our responses to Interrogatories 20 and 115 of CASE's Ninth Set. Therein, Applicants explained that the scope of Mr. Lobbin's review was primarily "the audit and vendor compliance function within the TUGCO QA organization."
Also, in response to Interrogatory 115 of CASE's Ninth Set, Applicants specifically stated that the scope of their response on vendor audits was " audits by TUGCO of vendors at the vendors' facilities." Further, Interrogatory 119 concerns a particular set of documents (" Vendor Compliance records") which Applicants previously made available to CASE for inspection and copying.
Accordingly, Applicants indicated to CASE that its present request for vendor audits by parties other than TUGCO should have been raised prior to the close of discovery rather than at this time. Nevertheless, Applicants will provide to CASE copies of Brown & Root vendor audits for AFCO Steel which CASE specifically identified in its telephone conversation on May 24, 1982.
Miscellaneous CASE also requested in its May 24 telephone call that Applicants identify the particular individuals who provided responses to each of the interrogatories in its Eighth through Eleventh Sets. As Applicants indicated in our telephone conversation on May 26, several people worked on those responses. Those persons were David N. Chapman, Antonio Vega, Susan L. Spencer, Homer C. Schmidt, John Marshall, and Lisa Bielfeldt. As Applicants also indicated, those persons worked together on providing responses to CASE's interrogatories and therefore no single individual could be considered to have provided any particular response.
Applicants indicated that the first three of those persons would be presented by Applicants as witnesses at the hearing and those persons would be capable of responding to CASE's questions regarding Applicants' responses to CASE's interrogatories.
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Mrs. Juanita Ellis .
May 27,'1982 Page 9 CASE also asked for a copy of the audit TDM-3. As Applicants indicated in our telephone conversation of May 25, CASE has already reviewed that audit but chose not to make a copy of it at the time it was reviewed. However, Applicants will supply a copy to CASE at this time.
Finally, CASE had a question with regard to an audit of
" excavation procedures" referenced in a January 1975 Brown &
Root Trending Report. Applicants have not been able to identify an " audit" on this matter. Applicants believe the term " audit" was incorrectly employed in the report.
Production of Documents The documents referenced above which Applicants are supplying to CASE will be available in Applicants Dallas offices on May 28, 1982.
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