ML20113E182
| ML20113E182 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/17/1985 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-186 OL, NUDOCS 8501230340 | |
| Download: ML20113E182 (7) | |
Text
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o on ATED CORRESPONDOC 1/17/85 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOALDi2:01 In the Matter of Docket Nos. 50-445 A [-
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and 50-446 V TEXAS UTILITIES ELECTRIC 113' 3
COMPANY, et al.
(Application for an Operating License)
(Comanche Peak Steam Electric Station, Units 1 and 2)
CASE'S FIRST SET OF INTERROCATORIES TO APPLICAN15 AND REQUESTS TO PRODUCE RE: CREDIBILITY Pursuant to the Boted's 12/18/84 MEMORANDUM (Reopening Discovery; Misleading Statement) (pages 9 and 10), CASE (Citizens Association for Sound Energy), Intervenor herein, files this, its First Set of Interrogatories to Applicants and Requests to Produce Ret Credibility.
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 affirnstion.
2.
Each interrogatory or document response should include all pertinent information known to Appiteants, their officers, directors, or employees, their agents, advisors, or counsel.
Employees is to be construed in the broad sense of the word, including specifically, Brown and Root Cibbs & Hill, Ebasco, Cygna, O. B. Cannon, any consultants, sab-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.
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3.
The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, audits, slides, internal memoranda.
informal notes, handwritten notes, tape recordings, procedures, specifications, calculations, analyses, and any other data compilations from which information can be obtained.
4.
Each document provided should include a sworn statement of its authenticity.
5.
Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory. Do not combine answers.
6.
Identify the person providing each answer, response, or document.
7.
These interrogatories and requests for nocuments shall be continuing in nature, pursuant to 10 CFR 2.740(e) and the pact 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.
8.
For each item supplied in response to a request for documents, identify it by the specific question number to which it is in i
response.
If the item is excerpted from a documment, identify it I
also by the name of the document.
Please also provide the copies in the entreet order (rather than in reverse order).
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i CASE'S INTERROCATORIES TO APPLICANTS AND REQUESTS TO PRODUCE 1.
Supply for inspection and copying: all documentation not already f
supplied regarding the liner plate documents for Unit 2; all i
documentation regarding the liner plate documents for Unit 1.
(CASE believes that Applicants are f amiliar with the documents we are requesting; however, if there is any question, please contact Billie t
Carde for detatis. Our request can be partially satisfied preliminarily by allowing a representative from CASE to go to the site and review the documents, then choose the specific ones of which we want copies.)
2.
Ret Protective Coatings:
i (a) Provide a list of all audits, reports, studies, and other compilations of information (from any and all sources) which have ever been done regarding the protective coatings at Comanche Peak.
If contained in a large document which covers many areas, provide also the page numbers where the information on protective coatings e
is contained.
(b) Provide all documents listed in (a) preceding, and all responnas and follow-ups to such documents, for inspection and copying.
(c) Provide a copy of the 1/20/83 Interoffice Memorandum to Doug Frankum from George Spires, under subject: " Optimizing Field Painting at Comanche Peak" (or something similar).
(d) Provide for inspection and copying all responses by Applicants to any notices of violation or other requests for information from
[
l the NRC regarding protective coatings.
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e (e) Provide for inspection and copying all documentation regarding I
certification and recertification of painters.
Include in your i
response: all documentation about individuals who failed tests and then were retested, how many failed, etc.; what the practice is now and has been in the past regarding the certification and I
recertification of painters; what procedures are now and have been i
in the past regarding the certification and recertification of painters.
(f) Has the practice in the past, or does the practice at this tire, regarding the certification and recertification of painters differed trou the procedures?
(g) If the answer (s) tn (f) preceding is yes, explain in detail how the practice differed from the procedures.
(h) Which of the docunents listed in (a) precedir.g was reviewed by J.
J. L1pinsky prior to his 9/28/84 Affidavit attached to Applicants' 9/29/84 Motion f or Sunmary Disponition Regarding Trip Report of J.
J. Lipinsky.# For each docunent, also indicate the date of such review, the extent of such review, and whether or not he was given a cony to review offsite.
(1) Which of the documents listed in (a) preceding was reviewed by J.
J. Lipinsky after his 9/28/84 Affidavit attached to Applicants' 9/29/84 Motion for Summary Disposition Regarding Trip Report of J.
J. L1pinsky. For each document, also indicate the date of such review, the extent of such review, and wnether or not he was given a copy to review offsite.
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This is the first of several such requests which CASE intends to file under this Board Memorandum. Since CASE's primary representative in the other-than-intimidation pertion of the proceedings is not familiar with the record f rom which the requests which are the subject of this First Set stem, we request oral argument at the ear'iest possible date; such oral argument will be handled by CASE's representatives in the intimidation portion of the proceedings, Ar.thony Rotsman or Billie Carde.
(If such oral argument is doae by telephone, Mrs. Ellis would also want to be included in the conference call.)
Respectfully submitted, 1c.c.Mt E
(tirm. ) Juanita Ellis, President DASE (Citizens Association for Sound Energy) 1426 S. Polk, Dallas, Texas 75224 214/946-9446 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINC BOARD in the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-1 COMPAriY, et al.
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and 50-446-1 (Comanche Peak Steam "lectric
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Station Units 1 and 2)
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l CERTIFICATE OF SERVICE By my signature below. I hereby certify that true and correct copics of CASE's First Set of Interrogatories to Applicants and Requests to Produce Re:
l Credibility 1
have been sent to the nar.es listed below this 17th day of January
,198 6,
l by,i Ly.pr,ess Mail wne re indicated by
- and First Class Mail elsewnere.
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- Administrative Judge Feter L. Bloch
- Nichola$ S. Reynolds, Esq.
- t. S. Nuclear Regulatory Comnission Disnop, Liecrean, Cool, Furc=11 4350 East / West Highway, 4th Floor
& keynolds Bethesda, Maryland 20S14 1200 - 17tF St., N. K.
kashin.tto, D.C.
2003e Judge E11: steth B..lonnson a
04.; RidFs Mational Lanorator" e Gear.
P.. "1:une.
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O. hoi *.. huildin; 35th Office of F.4c:utive Lers'.
Oai. Ridge. 1ennessee 3753; Dire: tor C. S. Nu: lear kegulatory Dr. Kenneth /.. LeCallom. Dear Commission Division of Engineering, Maryland National hane. Blo;.
Architecture and Tecnnology
- koom 10105 Oklahoma State University 7735 Old Georgetown hond i
Stillwater Oklahoma 74074 bethesda, Haryland 20S14
- Dr. Walter H. Jordan Cnairman, Atomic. Safety ans Licensing Carib Terrace Hotel board Panel 552 N Ocean Blvd.
U. S. huelcar Regulatory Comnission L
Poepano bench Florida 33062 hashington, D. C.
20$55 1
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l Chairman Renes Ilicks, Esq.
l Atomic Safety and Licensing Appeal Assistant Attorney General l
Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court building Washington,11. C.
20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.
l Regional Administrator, Region IV Trial Lawyers f or Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. m'., Suite 611 j
611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20036 Arlingten, Texas 76011 Mr. Owen S. Herrill Lanny A. Sinkin Staff Engineer Executive Director Advisorv Committee for Reactor faclear Information and hesuurce Sah'auards (:!S h-Idl6)
Service C. S. hucleat Regulatory Cometssion I
1346 Connecticut Avenue.
N.k.,
Washin; ton, D.
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20555 4th Floor Washington, D. C.
20036 Dr. David i;. holt:
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2012 S. Polk Dallas. Texas 75224 I
Michael D. Snence. Presioent Texas Utilities Generating Cumnany Skvvay Tower 400 horth Olive St., L.h. 81 Dallas, Texas 75201 Docketing and Service Section (1 copies)
Office of the Sc:retary C. S. f.uclear kegulator' Commisslor W a s h i n; t o r.. D.
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01r6.) Juanita Ellis, vresident
' CASE (Citizens Association for Sound. Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446
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