ML20087P874
| ML20087P874 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/07/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Horin W BISHOP, COOK, PURCELL & REYNOLDS |
| References | |
| OL-2, NUDOCS 8404090459 | |
| Download: ML20087P874 (5) | |
Text
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- C A S E =47 214/9M-94M (CITIZENS ASSN. FOR SOUND ENERGY)
'84 APR -9 A10 :42 April 7, 1984 Orr ;E OF 3Eca;-
000.E~.ING & SEn.
LRANCH EXPRESS MAIL Mr. William A. Horin, Esq.
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Bishop, Liberman, Cook, Purcell & Reynolds
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1200 - 17th St., N. W.
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Washington, D. C.
20036
Dear Bill:
Subject:
In the matter of Texas Utilities Electric Company, et al.
(Comanche Peak Steam Electric Station, Units 1 and 2)
Docket Nos. 50-445-2 and 50-446-2 Clarification of Wording of Portions of CASE's 3/14/84 Eighteenth Set of 1
Interrogatories and Requests to Produce' to Applicants This is to confirm our recent telephone conversations regarding subject pleading.
At your request on 3/5/84, I clarified by phone yesterday (3/6/84) the wording of Question 3 of subject pleading.
The clarified wording is attached.
(Please note that there are two slight changes in the wording I gave you over the phone yesterday:
On item (c),
" Counseling" should be changed to " Counseling reports;" and on item (d), "(b)(2)" should be changed to "(b's(3)." We hope that this clarifies exactly what we want.
Sincerely, CASE (Citizens Association for Sound Energy)
Mrs.) Juanita Ellis President Attachment cc: Service List - Docket Nos. 50-445-2 and 50-446-2 8404090459 840407 1
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Clarification of Wording of Question 3 of CASE's 3/14/84 Eighteenth Set of Interrogatories and Requests to Produce to Applicants:
The wording of Question 3 is clarified as follows:
3.
Supply for inspection and copying any and all documents between management (including supervisors, fo remen, middle management, upper management, etc.) and employees regarding the following:
(a) Any and all management / employee
- disputes, complaints, differences, and/or discussions pertaining to:
(1) policy disputes, complaints, differences, and/or problems regarding enforcement, application, or interpretation of procedures, instructions, or regulations relating to the job or work of the employee or of employees under his/her supervision (including, but not limited to, overinspecting, "knitpicking," etc.);
(2) intimidation, harassment,
- threats, pressure to meet production, or other kinds of pressure; (3) management directives (written or verbal) regarding the reporting of nonconforming conditions);
(4) and the like.
(b) Any and all letters of resignation by employees and responses by management in which such employees indicate concern or dissatisfaction with:
(1) the enforcement, application, or interpretation of procedures, instructions, or regulations relating to the job or work of the employee or of employees under his/her supervision (including, but not limited to, overinspecting, "knitpicking," etc.);
(2) intimidation, harassment,
- threats, pressure to meet production, or other kinds of pressure; a
(3) management directives (written or verbal) regarding the reporting of nonconforming conditions; (4) and the like.
(c) Counseling reports, termination reports, and exit interviews regarding (a) and (b) preceding.
(d)
Any and all proced'ures, instructions, regulations, and/or management directives (including those supplied by employees) involved in (a)(1), (a)(3), (b)(1), and (b)(3) preceding.
2
s Clarification of Wording of Question 3 of CASE's 3/14/84 Eighteenth Set of Interrogatories and Requests to Produce to Applicants (continued) 3.
(continued):
(e) Internal investigations conducted by management into such
- disputes, complaints, differences,
- problems, discussions, concerns or dissatisfaction, including those by the " ombudsman."
(f) Any and all internal files Applicants or their employees have on employees contacted by the NRC.
For purposes of your answer, the followinig definitions t; hall apply:
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, handwritten notes, tape recordings, calculations, and any other data compilations from which information can be obtained.
(See item 8, page 2, of CASE's 3/14/84 Eighteenth Set.)
The term " employees" shall be construed in the broad sense of the word and shall include Quality Control Inspectors, craftspeople, engineers, and any other employees employed by 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.
(See item 2, page 1, of CASE's 3/14/84 Eighteenth Set.)
The terms " procedures" and " instructions" shall be construed to include, but not be limited to:
the written or verbal procedures or instructions under which the employees work; the written or verbal methods of reporting of nonconforming conditions by means of nonconformance reports (NCR's), inspection reports (IR's),
component modification cards (CMC's),
design change authorizations (DCA's),
nondestructive examination reports (NDER's), field deficiency reports (FDR's), and/or any other method used f'or reporting nonconforming conditions.
The term " regulations" shall be construed to include, but not be limited to:
the Code of Federal Regulations (CFR), especially 10 CFR; Applicants' Final Safety Analysis Report (FSAR);
industry codes and practices; industry standards; etc.
e 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-2 1 -
COMPANY, et al.
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and 50-446-2 (Comanche Peak Steam Electric
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Station, Units 1 and 2)
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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 4/7/84 letter Applicants re: Clarification of Wording of Portions of CASE's 3/14/84 Eighteenth Set of Interrogatories and Requests to Product have been sent to the names lilsted below this 7th day of April
,19 8,_4_,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor Office of Executive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.
Architecture and Technology
- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Atomic Safety and Licensing Board 881 W. Outer Drive Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
- Herbert Grossman, Alternate Chairman Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Washington, D. C.
20555 i
1
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Alan S. Rosenthal, Esq., Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Dr. W. Reed Johnson, Member John Collins Atomic Safety and Licensing Appeal Regional Administrator, Region IV Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission 611 Ryan ?]aza Dr., Suite 1000 Washington, D. C.
20555 Arlington, Texas 76011 Thomas S. Moore, Esq., Member Lanny A. Sinkin Atomic Safety and Licensing Appeal 114 W. 7th, Suite 220 Board Austin, Texas 78701 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk 2
Michael D. Spence, President Dallas, Texas 75224 Texas Utilities Generating Company Skyway Tower Atomic Safety and Licensing Appeal 400 North Olive St., L.B. 81 Panel Dallas, Texas 75201 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20555 i
J jw, L fl1,1, i
s.) Juanita Ellis, President ASE (Citizens Association for Sound Energy)'
1426 S. Polk 2
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