ML20087F263
| ML20087F263 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/12/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8403190024 | |
| Download: ML20087F263 (9) | |
Text
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T w EL:o m enc:mg.g DCLKETED UNITED STATES OF AMERICA t!NC 3/12/84, NUCLEAR REGULATORY COMMISSION.
BEFORE THE ATOMIC SAFETY AND LICENSI GB RW N0:35 In the Matter of l
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APPLICATION OF TEXAS UTILITIES Docket Nos. 50-445 I
GENERATING COMPANY, ET AL. FOR AN OPERATING LICENSE FOR I
and 50-446 COMANCHE PEAK STEAM ELECTRIC I
STATION UNITS #1 AND #2 I
(CPSES)
CASE'S SEVENTEENTH SET OF INTERR0GATORIES AND REQUESTS TO PRODUCE TO APPLICANTS Pursuant to 10 CFR 2.740b and 2.741, CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Seventeenth Set of Interrogatories and Requests to Produce to Applicants.
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 perti-nent informa. tion known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel.
Employees is to be construed in the broad sense of the word, including specifi-cally Brown and Root, Gibbs & Hill, Ebasco, any consultants, sub-contractors, and anyone else perfonning work or services on behalf of the Applicants or their agents or sub-contractors.
3.
Each document provided should include a sworn statement of its authenticity.
8403190024 840312 PDR ADOCK 05000445 l
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4.
Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory.
Do not combine answers.
5.
Identify the person providing egcjt answer, response, or document.
6.
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 requcst that supplementation be made on an expedited basis.
7.
For each item supplied in response to a request for documents, identify it by the specific question number to which it is in response.
If the item is excerpted from a document, identify it also by the namo of the document.
Please also provide the copies in the correct order (rather than in reverse order).
8.
The tenn " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, slides, internal memoranda, hand-written notes, tape recording, calculations, and any other data compil'ations from which information can be obtained.
CASE'S INTERROGATORIES AND REQUESTS TO PRODUCE TO APPLICANTS All of the interrogatories in this pleading pertain to the "T-Shirt" Incident (see articles attached to CASE's 3/12/84 Motion for Discovery Regarding "T-Shirt" Incident, to which this pleading is attached).
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1.
How many quality control inspectors, wore the T-shirts?
2.
What specifically was printed on the T-shirts?
3.
Is there any validity to the alleged statement that craft workers had threatened to beat up the QC inspectors and rip the shirts off their backs?
4.
If the answer to 3. is yes, provide a brief explanation of the reasons you believe this to be true.
5.
If the answer to 3. is yes, provide for inspection and copying all documents (as defined on page 2, item 8, of this pleading) to support this conclusion.
6.
Explain the rationale for the actions by management, supervisors, etc.,
regarding this incident.
7.
Supply a brief chronology of events regarding the T-Shirt Incident (i.e.,
who first noticed the T-shirts and decided something should be done about them, at what time did that occur; who ordered that the QC inspectors who wore the shirts be confined in the room; who ordered that the QC inspectors be guarded during their confinement; who specifically, by name, went through the desks, lockers, and personal belongings of the QC inspectors while they were confined; l
etc.).
Include in your answer the specific names and titles of the individuals who initiated the various actions involved, who carried out the actions involved, and the approximate time of day when each event occurred (on both Thursday and Friday, 3/8/8a and 3/9/84, and on any other days where any action was taken regarding this incident.
l 8.
Supoly for inspection and copying all tape recordings, handwritten notes, or other documents (as.' defined on page 2, item 8) relating to any discussions, counseling, etc. between Applicants, their employees or others identified on page 1, item 2 of this pleading, including the ombudsman.
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s 9.
Supply for inspection and copying everything (documents, etc.) which was confiscated from the desks, lockers, etc. of the QC inspectors.
(Since this was reported to be a cardboard box filled 2 feet high with documents and personal items, we will want to have this provided in one stack so that we can get an idea of the actual size of the stack.)
10.
It is cur understanding that some personal items were returned to the inspectors. Provide a list of the specific items which have already been returned and to whom they were returned.
11.
P. ovide the names of all QC inspectors who wore the T-shirts.
(Ifthe inspectors themselves do not want their names provided to the public, please 3
provide some sort of documentation to this effect from the inspectors to the Board and we will be willing to discuss a protective order in this regard.)
12.
Provide the names of all other QC inspectors in the particular group to which the QC inspectors who wore the T-shirts belonged.
(See comment regard-ing protective order in 11. preceding.)
- 13. Did management or others go through the desks, lockers, and personal belongings or QC inspectors other than those who wore the T-shirts?
14.
If the answer to 13. is yes, provide the names of those inspectors.
(See comment regarding protective order in 11. preceding.)
15.
If the answer to 13. is yes, was there any effort made to keep the items cor.fiscated from the inspectors who wore the T-shirts separated from the items confiscated from the inspectors who did not wear the T-shirts?
16.
If the answer to 15. is yes, how were they separated?
17.
If the answer to 15. is yes, when you provide for inspection and copying those documents, includs a note or other identification on those items.
/
18.
Provide a statement as to whether or not any changes were made on any (as defined on page 2, item 8) of the documentsfin any way prior to the time the Board ordered that they be retained in their current form.
Include in your statement what specific changes were made and the reason for such change, as well as the name of the individual (s) who made such changes.
19.
Include a statement which confinns that all documents, tape reco; dings, etc. requested have actually been provided to CASE (to be supplied when we look at the documents, etc.).
- 20. What specific actions were taken (if not already discussed in previous answers) by management, etc., towards the employees who wore the T-shirts or who were in the group with the employees who wore the T-shirts? (Please indicate if already included in previous answers.)
- 21. Have any of the QC inspectors involved (who wore the T-shirts or who are in the group with them) quit?
22.
If the answer to 21. is yes, provide the names and addresses of such inspectors.
- 23. Was the NRC contacted prior to management's taking any action regarding this matter?
24.
If the answ'er to 23 is yes, provide the name and title of the individual who contacted the NRC, as well as the name and title of the individual with the NRC who was contacted.
25.
If the answer to 23. is yes, at what time of day was the NRC contacted?
26.
If the answer to 23. is no, at what time of day and during what phase.
of events was the NRC contacted.
27.
If the answer to 23. is no, provide the name and title of the individual who contacted the NRC, as well as the name and title of the individual with the NRC who was contacted.
~,
- 28. What rationale was given by the QC inspectors for wearing the T-shirt 3?
i
- 29. During any of the interviews, discussions, etc., following the wearing of the T-shirts, did any of-the QC inspectors express concern in any manner regarding changing of quality control procedures?
i 30.
If the answer to 29. is yes, supply complete details regarding such discussions, etc., and their concerns.
31.
If the answer to 29. is yes, supply the name(s) and addresses of such QC inspectors.
32.
If the answer to 29. is yes, supply for inspection and copying all such procedures, including the original and all revisions.
33.
If the answer to 29. is yes, explain the rationale for changing the procedure (s).
- 34. What was the response of the NRC representative identified in 24. or
- 27. to management's actions? Please give specific details.
- 35. What did the individual who contacted the NRC (identified in 24. or 27.) tell the NRC representative? Please give specific details.
36.
Provide a summary of any and all telephone calls between the QC inspectors who wore the T-shirts (and the QC inspectors who were in the same group with them), and any of Applicants'. employees (as defined under ~ item 2'on page 1).
Give full and specific details (such as who, what, when, where, etc.).
- 37. Have the QC inspectors who wore the T-shirts and the other QC inspectors who were in the same group with them been split up in any way?
38.
If the answer to 37. is yes, provide specific details,~ including names, etc.
l l
- 39. Have any of the QC inspectors who wore the T-shirts or the other QC inspectors who were in the same group with them been reassigned, or have their duties been changed in any way since the T-shirt incident on Thursday, 3/8/84?
40.
If the answer to 39. is yes, supply complete details, including names, etc.
Respectfully submitted, imb fAAL>
(#36.) Juanita Ellis, Prbsident BASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 f
~'
w UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFO.'.E THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I
I TEXAS UTILITIES GENERATING I
Docket Nos. 50-445 and COMPANY, et al.
l 50-446 I
(Comanche Peak Steam Electric Station i Station, Units 1 and 2) l CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE'S SEVENTEENTH SET OF INTERROGATORIES AND REQUESTS TO PRODUCE TO APPITCANTS have been sent to the names listed below this 12th day of March
, 1984_.
by:
Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter _ B. Bloch Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Panel 4350 East / West Highway, 4th-Floor U. S. Nuclear Regulatory Cannission Bethesda, Maryland 20814 Washington, D. C.
20555
- Dr. Kenneth A. McCollom, Dean Alan S. Rosenthal, Esq., Chairman Division of Engineering, Atomic Safety and Licensing Appeal Architecture and Technology Board Oklahoma State University U. S. Nuclaar Regulatory Commission Stillwater, Oklahoma 74074 Washington, D. C.
20555
- Dr. Walter H. Jordan Dr. W. Reed Johnson, Member 881 W. Outer Drive Atomic Safety and Licensing Appeal Oak Ridge, Tennessee 37830 Board U. S. Nuclear Regulatory Commission
- Nicholas S. Reynolds, Esq.
Washington, D. C.
20555 Bishop, Liberman, Cook, Purcell
& Reynolds Thomas S. Moore, Esq., Member 1200 - 17th St., N. W.
Atomic Safety and Licensing Appeal Washington, D. C.
20036-Board U. S. Nuclear Regulatory Commission j
- Geary S. Mizuno, Esq.
Washington, D. C.
20555 l
Office of Executive Legal Director l
U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal l
Maryland National Bank Building Panel 7735 Old. Georgetown Rord - Room 10105 U. S. Nuclear Regulatory Commission Bethesda, Maryland 26814 Washir.gton, D. C.
20555 l
l l
d
Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Canmission Washington, D. C.
20555 Renea Hicks, Esq.
Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 R. J. Gary, Executive Vice President Texas Utilities Generating Co.
2001 Bryan Tower Dallas, Texas 75201 1
3 Ms.) Juanita Ellis, President MASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 l