ML20126K980

Interrogatories Concerning Premature Implementation of Comanche Peak Review Team,Including Requests Re Reinsp Efforts Completed to Date.Certificate of Svc Encl.Related Correspondence

ML20126K980
Person / Time
Site:	Comanche Peak
Issue date:	07/25/1985
From:	Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
References
CON-#385-989 OL-2, NUDOCS 8507300539
Download: ML20126K980 (6)

Text

-- ,

• 4 ig1AGD cuit*:lWWDN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BOCKETED U%RC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 535. 29 N1 :07

) 50-445-2 TEXAS UTILITIES ELECTRIC ) and 50-446-2 COMPANY, et al. ) 0FFICr 0F SECRETARY

- 00CKfTING A SERVICf.

) ^"

(Comanche Peak Steam Electric ) (Application for an station, Units 1 and 2) ) Operating License)

CASE INTERROGATORIES REGARDING PREHATURE IMPLEMENTATION OF CPRT Pursuant to the Nuclear Regulatory Commission Rules of Practice, 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, and should include a sworn statement of the truthfulness of the answer, signed by the specific individial who answered and has personal knowledge of the matter under discussion.

2. Each document should include all pertinent information known to : Applicants, their officers, directors, or employees, their agents, advisors, or counsel.

The term " employees" is to be construed in the broad sense of the word, including specifically (but not limited to): Brown &

Root, Gibbs & Hill, Ebasco, Cygna, O.B. Cannon, any consultants, sub-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.

terms " documents" and " documentation" shall be con-

3. The 8507300539 850725 PDR ADOCK 0D000445 1 0 PDR

]

/

^ .

e .

( ,

A- n strued in'the broad sense of the wordu and shall include.ar.y.and all writings, graphs, $ harts, .ph otograph s,freports, '

studies, audits, microfiche, slidee, internal memoranda, informal not'as, handwritten notes, tape reecrdings, procedures', .specifica tfions calculations, ' pnafyses and any other data compilations frok which

-i/

information can be obtained. Incl 3de prindyouts of any and all such information which are contained on computer discs or in

) .

I i_ l ,

computerized files or similar files. ' ' >

The term " documents" shall also include any and a l3.

contracts, letters of understanding, letters of intenE, purchase orders, statement of protocol, statement of scope, any'and all

/

other rela'ted or similar' documents, and all 'other pertinent I

r information.

4,. Each document provided should include a sworn statement of its authenticity, signed by each specific individual who has personal knowlege of the document.

5. Adswer each interrogatory in the, order in whica it is i

asked, numbered to correspond to the number ,of the ninterogatory.

Do not combine answers.  :

6. Identify the person previding each answer, response, or document.

7. These interrogatories end 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 I

restrictions under which we are presently working, we request that supplementation be made on an expidited basis.

8. For each item supplied in response to a request, for docu-ments, identify it by the specific question number to'which it is 2 t 3

h in response. If the item is excerpted from a document, identify it also by the name of the document.

REQUESTS

1. What reinspection effort has been completed to date on issues identified by the NRC's Technical Review Team?

2. Identify each system, component, or piece of hardware which has undergone any review, or reinspection by Texas Utilities or any of its contractors.

3. For each system, component, or piece of hardware which has been reviewed or reinspected identify the person, persons and/or organization conducting the reinspection.

4. For each system, component, or piece of hardware which has been reviewed or reinspected identify and, produce the procedures used to conduct the reinspection or review.

5. For each system, component, or piece of hardware which has been reviewed or reinspected identify the results of the reinspection or review; if no documentation was produced to record specific findings identify for deposition the person or persons who conducted the analysis.

6. For each system, component, or piece of hardware which has been reviewed or reinspected identify all trending documents prepared which detail the significance of the identified problems.

3

a e

.y

7. For each system, component, or piece of hardware which is to be reviewed or reinspected in the CPRT effort (including the self-initiated evaluations) provide a schedule of when such reinspection will commence.

Respectfully Submitted,

/'

v4 D Anthony Z. ism

),

/

Billie Gar /

, Trial La era or Public 2000 P Street,-N.W.

Suite 611 Washington, D.C. 20036 (202) 463-8500 Counsel for CASE I

i e

4

r, -.

T

.. gEt ATED CORRESPONDE3CO July 25, 1985

~

~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ggcggigg USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 15 JUL 29 All:07 In the Matter of )

) 0FFICE OF SECRF.TAF Y TEXAS UTILITIES GENERATING ) 00CXETING & SERVILI:

COMPANY, et al. ) Docket Nos. 50-445-2 BRANCH

) and 50-446-2 (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's CASE Interrogatories Regarding Premature Implemenation Of CPRT have been sent to the names listed below this 25th day of July, 1985, by: Express mail where indicated by *; Hand-delivery where indicated by **; and First Class Mail unless otherwise indicated.

I Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Herbert Grossman Alternate Chairman ASLB Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074

, u t

Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 .

Ms. Ellen Ginsberg, Law Clerk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert JL. Wooldridge, Esquire Worsham, Forsythe, Sampels

& Wooldridge 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Nicholas Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, N.W.

Washington, D.C. 20036  :

Stuart Treby, Esquire Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk Dallas, Texas 75224

- - ~

l gf 64' ANTH OISMAN

. .