ML20128N368
| ML20128N368 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/28/1985 |
| From: | Roisman A TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Wooldridge R WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| References | |
| CON-#285-227 OL-2, NUDOCS 8506030250 | |
| Download: ML20128N368 (6) | |
Text
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Robert Wooldridge, Esquire BRANCH Worsham, Forsythe, Sampels i
& Wooldridge e.
2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Ret In the Matter of Texas Utilities Generating Company, et al. (Comanche Peak Steam Electric Station, Units 1 and 2), Docket Nos. 50-445-2 and 50-446-2 Dear Bob In our recent conference call Judge Bloch suggested that we attempt to utilize-the current haitus in the hearings to j'
conduct informal discovery.
In keeping with our mutual interests of moving these proceedings along as quickly as possible, CASE requests that the following documents be provided for our review 4
I and inspection.
.l.
Management and job responsibility changes.
a.
All internal memoranda reflecting the actual changes in management at Comanche Peak, the basis for those changes, and the justification of those changes given to the individual including minutes of all meetings, minutes of briefings of the Board of Directors, the CEO, other owners of Comanche Peak; all the written explanations provided to the individuals removed, transferred, demoted, reassigned, or in any other way affected by management changes.*/
- / Throughout this request " documents" include documents in the possession of applicant and any of its owners, contractors, subcontractors, consultants, employees, officers and directors.
" Documents" encompasses the usual range of handwritten notes tapes, videos, word processing discs, drafts, extra copies with distinguishing markings on them, etc.
O' 8506030250 850528 VOlECT OF THE CITIZENS LECAL CLINIC h
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t Robert Wooldridg3, Ecquiro May 28, 1985 Page Two b.
All notes of conversations between NRC officials recommending or suggesting any management, changes, or any dissatisfaction with specific individuals performance or the attitude of management in general.
c.
A complete, up-to-date list, including an organi-zational chart contract for all personnel doing work on design l
issues, and other areas relevant to Contention 5.
This should be comprehensive to ist line supervisors.
Include in this list the present job of any person who was a witness for any party in Docket 2 if at the time they testified or were deposed they 1
worked for applicant, other owners, contractors, with sub-contractors or consultants at the plant.
h d.
All documentation, including contracts between TUGCO and any other company setting forth the agreements which govern or control the assignment parameters of all individuals identified in Items a and c.
e.
The job evaluations, performance ratings, letters of recommendation or, if appropriate, letters of resignation, and any other documents relevant to all personnel changes identified in Items a and c.
Where no such document exists but the substance of an evaluation, or the basis for a resignation or termination (transfer, etc.) was provided in the context of a meeting, identify all such meetings and provide all minutes or notes of those meetings.
i '
f.
In addition to Items a-e, for any Applicant witness who has given testimony [upon which the ccmpany intends to rely to prove their case] identify any job or responsibility change (i.e., Mr. Hayward Hutchinson former Docket Control Supervisor, testified in February 1984 regarding the pre-notification of the October 1983 CYGNA audit.
Subsequently Mr.
Hutchinson was transferred to the position of Unit II paper flow group task force supervisor.
(See testimony of H. Hutchinson in D.O.L. proceeding of D. Hatley, Feb. 10, 1985) and provide all documents relevant to the reason for and nature of that change.
g.
For each personnel change identified in any of the above responses provide the naw job description, or memorandum of instructions, detailing the scope of responsibility and authority to each individual.
Also included in this item is any memorandum, notes, etc. generated by the incoming official setting forth his/her understanding of the job and any instructions,, comments, overviews, etc. generated by the new manager to his/her subordinates.
T q
Robert Wooldridgs, Ecquiro May 28, 1985 Page Three h.
Any other document which bears on the overall personnel and management changes from January 11, 1985 to present.
Identify all speeches given by TUGCO or Brown and 2.
a.
Root management personnel to the Comanche Peak workforce (or any group thereof), both QA and OC, regarding organizational or management changes at Comanche Peak, including but not limited to M r. Spence's March / April speeches to the QC inspectors about the problems and status of the plant.
b.
For each communication identified, provide the 6
written record of that communication, any transcripts or notices of speeches or meetings, and all written records of the results of those communications.
3.
a.
All documents provided to the owners or stockholders of TUEC developed to detail the status of the plant, problems at the plant, the status of licensing, the changos being made by TUEC to address those problems, etc.
b.
All documents provided at meetings and documents of meetings between owners, stockholders, investors, investment advisers, bankers or similar persons who have money invested in CPSES or are being encouraged to invest in CPSES which provide explanations about the status of licensing, problems in the plant, status of the plant, management changes, etc.
4.
a.
All documents which relate to the basis for the removal or elimination of the ombudsman position, and any i
documents which recommend, justify, announce and or explain the j
replacement of the ombudsman program with the SAFETEAM.
t b.
The contracts and agreements about the scope of I
work between the SAF2 TEAM and TUEC and/or Brown and Root, Inc.
I c.
All written information regarding how the SAFETEAM implements its program; methodology, instructions, training materials, forms uced in interviews, interview checklists.
l d.
All material developed by the SAFETEAM about alle-l gations of harassment, intimidation, threats or influence of QC l
inspectors prior to June 30, 1984.
e.
All documents provided by the SAFETEAM to TUEC about harassment, intimidation, threats or influence of QC inspectors from June 30, 1984 to present.
l 1
I i
l
Pt 0 -
Robert Wooldridga, Ecquiro M y 28, 1985 Page Four 5.
All documents provided to, including all written records of personal or telephonic communication or meetings with, the Department of Energy task force on nuclear energy relevant to Comanche Peak including the status of licensing, the hearings, and the status of the construction of Comanche Peak.
6.
All documents provided to, including all written records of personal or telephonic communication or meetings with, any person working at or for the White House, including the cabinet level committee on energy issues, relevant to Comanche Peak including the status of licensing, the hearings, and the status of the construction of Comanche Peak.
7.
All documents provided to, including all written records of personal or telephonic communication or meetings with, the Department of the Treasury's task force on nuclear energy relevant to Comanche Peak including the status of licensing, the hearings, and the status of the construction of Comanche Peak.
8.
All documents provided to, including all written records of personal or telephonic communication or meetings with, Senator Thomas Bevill, Congressman Morris Udall, Congressman James Bryant, Congressman James Wright, and any other members of Congress or the Texas state legislature or their staff, about the status of licensing, the hearings, and the status of the construction of Comanche Peak.
9.
All documents provided to, including all written records of pernonal or telephonic communication or meetings with, Victor Stello and Harold Denton about the status of licensing, the hearings, and the status of the construction of Comanche Peak.
10.
All documents provided to, including all written records of personal or telephonic communication or meetings with, William Dircke about the status of licensing, the hearings, and the status of the construction of Comanche Peak.
11.
All documents provided to, including all written records of personal or telephonic communications or meetings with, any of the NRC Commissioners or any member of their staff about the status of licensing, the hearings, and the status of the construction of Comanche Peak.
12.
a.
All documentation prepared by, or for, or under the control of the CPRT that relates to review of the TRT findings, beginning with any such documents generated in response to the September,1984 letter f rom the TRT to TUEC on electrical problems, and including the October, 1984, November, 1984 and
ig b
2 Rnbert Wooldridg2, Ecquiro May 28, 1985 Page Five January 11, 1985 letters, and the subsequently issued SSER Nos.
7, 8 9 and 10 inluding all documents prepared for or as a result of any meetings with any representatives of the TRT.
b.
All CPRT documents which address the validity, significance, and generic impact of the TRT findings.
13.
All documents (including CPRT)) which evaluate, report, assess, analyze or detail the CYGNA corporation's Phase IV findings with regard to QA/QC issues, i.e.,
CYGNA'is finding that the cause of the design review problem was with the reviewers, not the procedures, but couldn't explain why the reviewers weren't doing their job, or CYGNA':s inability to determine why e
the design document control system broke down.
14.
a.
All documentation, including contracts between TUEC, Brown and Root, or other subcontractors (such as EBASCO) which defines the scope of the assignments of contract personnel who have been retained by Applicant to provide assistance of any sort in resolving QA/QC or hardware concerns identified by the NRC--i.e.,
all contractors hired after March 19, 1984 up to and including the present.
b.
The contract and all other documents related to the scope of responsibility of Daniels International at Comanche
- Peak, c.
The contract and all other documents related to the scope of responsibility of Stone and Webster at Comanche Peak.
d.
The contract and all other documents related to the scope of responsibility of Tera Corporation at Comanche Peak'.
e.
The contract and all other documents related to the scope of responsibility of Evaluation Research Corporation at Comanche Peak.
f.
The contract and all other documents related to the scope of responsibility of Monty Wise, Inc. at Comanche Peak.
i g.
The contract and all other documents related to the scope of responsibility of any other independent contractor and/or consultant at Comanche Peak.
l 15.
All documentation that explains the relationship between all of the subcontractors identified in response to any question above and TUEC.
8 4.
Rcbert Wooldridg2, Ecquiro M y 28, 1985 Page Six 16.
All documents which contain scheduling forecasts for e
implementation of any reinspection or corrective action program which were provided to outside consultants, the Securities Exchange Commission, the Department of Energy, any bond broker or other investors, potential investors or investment advisers the Board of Directors, other owners of Comanche Peak, any other government agency, or any. state or local officials or employees.
1 This request is not intended to be comprehensive but should give you a good sense of the type of information we are seeking.
To the extent any request is deemed by you to be outside the e
scope of Docket 2 we are authorized by Ms. Ellis to state that the request should be considered a Docket 1 request.
Since this is an informal request, as suggested by Judge Bloch, there is no time limit but we would appreciate a written indication from you within the next week regarding your willingness to participate in this informal discovery and your anticipated schedule for response.
Please call if you have any questions.
I Sincerely,-
nthony Z Roisman Executiv Director i
l AZR:dle f
cc:
Dockets 1 & 2 Service List M
o a
.