ML20087G453
| ML20087G453 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/14/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8403200026 | |
| Download: ML20087G453 (5) | |
Text
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net >MD 3/T4 8 ED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION M MR 19 pyg;IO BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s'hh)$
in the Matter of G
3 RANCH APPLICATION OF TEXAS UTILITIES I
I Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR AN OPERATING L'ICENSE FOR I
and 50-446 COMANCHE PEAK STEAM ELECTRIC I
STATION UNITS #1 AND #2 (CPSES)
CASE'S EIGHTEENTH SET OF INTERROGATORIES 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 Eighteenth 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 affimation.
2.
Each interrogatory or document response should include all perti-nent infoma. 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 performing 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.
8403200026 840314 PDR ADOCK 05000445
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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 each 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 request 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 name of the document.
Please also provide the copies in the correct order (rather than in reverse order).
8.
The term " 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 compilations from which information can be obtained.
CASE'S INTERROGATORIES AND REQUESTS T0 PRODUCE T0' APPLICANTS l
The following interrogatories and requests to produce ' concern the issue of intimidation,. harassment, and threatening of QC inspectors and other employees at Comanche' Peak. The Licensing Board has stated-that hearings will be held-on this issue (see _12/28/83 Board Memorandum and Order (Scheduling' Matters))..
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1.
Do Applicants have any kind of system set up to receive complaints or
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to discuss concerns from QC inspectors or other enployees at Comanche Peak?
2.
If the answer to 1. is yes, please give specific details regarding the type of system (s), who is involved in the system (s) (including names and titles), how the system works, how enployees are informed of the system, etc.
It is CASE's understanding that recently Applicants have hired an ombudsman.
Include in your answer details regarding each system which currently exists or has existed in the past at Comanche Pea k.
3.
Supply for inspection and copying all documents (as defined in item 8 on page 2 of this pleading) of all management / employee disputes, com-plaints, or discussions regarding work of QC inspectors or workers, including letters of resignation by employees, letters to supervisors or management by suployees, complaints to management or supervisors, etc.
Respectfully submitted, ffA '.s M'rs.) Juanita Ellis, President f} CASE (Citizens Association for Sound Energy 1426 S.- Polk Dallas, Texas 75224 214/946-9446
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPf4ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l
l 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 s
By my signature below, I hereby. cer.tify that true and correct copies of CASE'S EIGHTEENTH SET OF INTERR0GATORIES AND REQUESTS TO PRODUCE TO APPLICANTS have been sent to the names listed below this 14th day of March
, 198 _,
4 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 Commission Bethesda, Maryland 20814 Washington, D. C.
20555 Dr. Kenneth A. McCollom, Dean Alan S. Rosenthal, Esq., Chainnan Division of Engineering, Atomic Safety and Licensing. Appeal Architecture and Technology Board Oklahoma State University U. S. Nuclear 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, Tennes'see 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-
- Geary S. Mizuno, Esq.
Washington,-D. C.
20555 Office of Executive Legal Director U. S. Nuclear Regulatory Conmission Atomic. Safety and Licensing. Appeal Maryland National Bank Building Panel 7735 Old. Georgetown Road -- Room'10105 U. S. ' Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington. D. C.
20555 T
Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission 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 7601.1 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
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's.) Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 l
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