ML20133K769
| ML20133K769 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/18/1985 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#485-862 OL-2, NUDOCS 8510220293 | |
| Download: ML20133K769 (30) | |
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October 18'Se-1985"'
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.A s a',; r. 4 e i UNITED STATES OF AMERICA y'/%
NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
i TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445-2 COMPANY, et al.
)
)
and 50-446-2 (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
APPLICATION FOR ISSUANCE OF SUBPOENAS i
DUCES TECUM FOR NRC STAFF WITNESSES CASE requests that the Board issue the attached subpoenas duces tecum to the following named NRC Staff members pursuant to 10 C.R.F. 2.720(h)(2)(i):
Mr. Vince Noonan Mr. Thomas Ippilito Mr. Herbert Livermore Mr. Jose Calvo Mr. Larry Shao Mr. Conrad McKracken Mr. Richard Bangert According to Section 2.720(h)(2)(1),
'tin a proceeding in which the NRC is a party, the NRC Staff will make available one or more witnesses designated by the Executive Director for i
Operations (EDO) for oral examination at the hearing or on deposition regarding ary matter, not privileged, which is relevant to the issues in the proceeding."
Further, this section states that " attendance and testimony of the Commissioners and named NRC personnel" may not be required by the presiding officer officer, by subpoena or otherwise: Provided, that the presiding 8510220293 851018
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officer may, upon a showing of exceptional circumstances, such as j
a case in which a particular named NRC employee has direct personal knowledge of a material fact not known to the witnesses made available by the EDO require the attendance and testimony of i
named NRC personnel.
(emphasis added)
To date the NRC Staff has not named the witnesses it intends i
to call to support its position in this case.
However, it is clear that the Staff position will be based on the Technical Review Team's work as presented in SSERs 7, 8,
9, 10 and 11, and that the Board considers the SSERs extremely important j
(Memorandum, Importance of SSERs, April 30, 1985).
Each of the i
j named individuals, with the exception of Mr. Noonan and Mr.
1 4
Ippilito, were group leaders for specific SSERs.
Mr. Noonan, 1.
and Mr. Ippilito before him, managed the TRT effort which began 2
in March of 1984.
Intervenors request that the depositions be scheduled for October 29, 30 and 31.
These dates are prior to the November 5 and 6 meeting between the Staff and the Applicant regarding the responses to the Staff questions on the CPRT.
Our request is i
consistent with the request we have been pursuing informally, 1
Mr. Jose Calvo was the group leader for electrical issues, Mr.
Richard Bangert for miscellaneous items, Mr. Larry Shaw for mechanical / civil / structural, Mr. Herb Livermore for QA/QC, and i
Mr. Conrad McKracken for paint coatings.
2 4
Mr. Thomas Ippilito was in charge of the Special Review Team's April 1984 inspection and the production of the July 13, 1984 SRT i
l, report (Letter from Darrell Eisenhut to Michael Spence, TUGCO, re: Report of the Special Review Team), and of the Technical i
Review Team work through October 1984 when Mr. Ippilito resigned aa head of the TRT and Mr. Vince Noonan was appointed.
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1
. l albeit unsuccessfully, with the Staff since March 1985.
)
Intervenors' urgent request is prompted by recent events which convince us that the discovery blackout which Intervenors j
have been required to tolerate has now placed CASE at a
]
significant disadvantage in relation to events which are scheduled to occur within the next several weeks.
First, we know l
that the CPRT reinspection effort, although not yet formally a
approved by the Staff, is 38% completed.
(See statements of John Beck in Ft. Worth Star Telegram, October 11,1985 (Attachment 1)).
1 We understand that Applicants will seek to have the Staff accept the work they have already completed, and that will be on their agenda for the November 5 and 6 meeting between the Staff and i
{
Applicant.
l We also have been told that the NRC Staff approval of the j
CPRT is being predicted within a month.
Theoretically it will be based on the Staff's analysis of the adequacy of the reinspection i
plan to resolve those specific and generic issues raised in the l
SSERs.
CASE's comments on the plan, pro or con, will be
{
effectively irrelevant after Staff approval is given.
Simultaneously, in this hearing, CASE is expected to identify any j
problems or deficiencies in the CPRT plan prior to resubmitting our request for an evidentiary standard and Board action l
regarding the CPRT.
(See Board Order denying CASE's request for l
an evidentiary standard, March 12, 1985).
CASE will be unable to protect its interests without access to the basis of the TRT's I
findings and conclusions.
I l
Additionally, CASE faces a continuing defense by the I
i i
. Applicant that the issue of specific deficiencies or a pervasive QA breakdown is irrelevant based on the existence of the CPRT Program Plan.
CASE cannot demonstrate the inadequacies in the CPRT to address the identified deficiencies without having the basis for the Staff's conclusions.
Nor can CASE evaluate the adequacy of the CPRT Issue Specific Action Plans (ISAPs) without i
knowing the basis of the Staff's findings and conclusions as outlined in the SSERs.
1 The Applicant has had the benefit of numerous meetings, conversations, communication with the Staff since January, as i
they sought to understand the basis of the various Staff t
conclusions and findings in order to develop their plan.
CASE has not been a party to those communications.
Only after we fully understand the basis of Staf f findings and conclusions will we be able to agree or disagree with Applicants' specific proposals, the scope of the CPRT program, or the merits of their position.
Finally, CASE now learns -- through the press -- that Applicant anticipates going to hearing in January or February.
Following nine months of discovery and information blackout from both the Applicant and the Staff, CASE has significant amounts of work to do prior to hearings.
That work cannot begin until we have had adequate discovery.
The cornerstone of the remaining i
work is discovery into the Staff's conclusions.
j We are prepared to cooperate on this matter in any way -- we will ccnduct the depositions as evidentiary depositions to save substantial hearing time, we will delay the depositions if the Staff goes forward with its long promised CASE-Staff meeting
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prior to the November 5, 6 CPRT meeting.
However, we believe it is critical that such a meeting be scheduled prior to the November meeting with Applicant.
By way of background to this request, the information sought here is more than ripe for discovery.
It has now been over a year since the TRT members completed the majority of the actual site inspection work that served as the basis for the various conclusions in the SSERs, and months since the majority of the written work was completed on the SSERs which are now issued.
Additionally we have attempted to pursue this information informally for over six months.
Intervenors first sought depositions of ten named Staff members in a March 29, 1985 letter from Stuart E. Treby, Esq. to Anthony Z. Roisman, Esq., in which we sought discovery on the basis of the TRT findings as reflected in the SSERs available at the time.
After SSER 11 was issued CASE again sought to have the preliminary meeting scheduled with the Staff.
We formally requested that meeting again in a July 17, 1985 letter to Mr. Treby.
Following that letter the Staff agreed to make the appropriate knowledgeable individuals available informally for a " meeting" with the Intervenors, after the issuance of the original SSERs.
This position was discussed and confirmed in numerous telephone conversations between counsel.
That meeting has been scheduled and postponed at least three times since July, and now appears to be postponed until the completion of the Staff's work on approving the CPRT.
That significant schedule change was never agreed upon between Staff and CASE.
It has always been our position that we needed the l
l basis of the Staff's findings before we could take our final position on the CPRT.
Intervenors originally agreed to a meeting instead of depositions at the Staff's request.
We have operated on a good faith belief that a meeting with the individuals named below would have been held informally months ago, prior to any formal depositions, and prior to a final CPRT.
However, based on the most recent cancellation of that meeting with no reschedule date, as well as the announced intention by Applicant to move these matters to hearing in January or February of 1985, CASE believes that it has no choice but to formally move for these depositions immediately.
We have included supboenas duces tecum for the named individuals, all of whom have direct material knowledge about the issues in the SSERs for which they were responsible, as defined by 10 C.F.R. 2.7200(h)(2).
Respectfully submitted, 3.
M S N'b c - ( w ANTHONY Z.
ROISMAN Trial Lawyers for Public Justice, P.C.
2000 P Street, N.W.,
Suite 611 Washington, D.C.
20036 (202) 463-8600 Counsel for CASE
(
October 18, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
)
Docket Nos. 50-445-2
)
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 Application For Issuance Of Subpoenas Duces Tecum For NRC Staff Witnesses have been sent to the names listed below this 18th day of October, 1985, by:
Express mail where indicated by *; Hand-delivery where indicated by **; and First Class Mail unless otherwise indicated.
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
2 [
' I 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
?
I Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels
& Wooldridge 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Nicholas Reynolds, Esquire Bishop, Liberman, Cook, l
j Purcell & Reynolds 1200 17th Street, N.W.
j Washington, D.C.
20036 Stuart Treby, Esquire Geary S. Mizuno, Esquire l
Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1
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 l
Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk 1
Dallas, Texas 75224 Mr. W.G. Counsil l
Executive Vice President Texas Utilities Generating Co.
i Skyway Tower, 25th Floor 400 N. Olive Streut i
Dallas, Texas 75201 4
m.
Mr. Roy P.
Lessy, Jr.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Mr. Thomas G.
Dignan, Jr.
Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110
( (oNGA 3 t-i W Cs~
AN'rHOg Z.
ROISMAN 4
I
Enitch 9tates of America NUCl. EAR REGULATORY COMMISSION O
In the nutter of:
TEXAS UTILITIES GENERATING COMPANY, et. al.
(Comanche Peak Steam Electric Station,
>. DOCKET NO.
50-445-2 Units 1 and 2) 50-446-2 TO Mr. Vince Noonan U.S. Nuclear Regulatory Commission Washington, D.C. 20555 YOU ARE HEREBY COMMANDED to appear...1.5556.. Connecticut.. Ave.....NW.
Mte..2.Q2...................................................................................................
in tt. _ y o f.......W#.h.i.n 919a r....D,., p,,.,,,,,, y,,,,,,),,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,..........
on the...... 2 9........ day of.......Wt.9hr.......19...M.....a t........ 9.i.Q.0..... 0' clock AM.
to testify on behalf of.........C1.tizens.. Association...for.. Sound... Energy...(. CASE) in the above entitled action and bring with you the document (s) or object (s) descrioed in the attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD BY l
Anthony Z. Roisman, Esq.
l mORNEY FOR f'A M *
- 19........
l onnn o et ygg, - 3 gli M
hingten, D.C.
20036 i
TELEPHONE f9n?) M a-M i
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l 10 C.F.R. 2.120 (i) pers, ding ofiscar or. of he at unvassable, the l
On motion mado promptt>, and in any twnt commission may (I) quaan or modtry the sub-l se or before the nme spectisee in the subpoena poena of er is unreasonsste or requires evidence i
for compliance by the person to whom the sub.
not relevant to any matter in issue, or (2) con-poena is derreted. and on nonce so the party at dttton dental of the mornon on lust and reasonable m*ose snarance the subpoena.as nssued. the terms
RETURN ON SERVICE Received this subpoena at..
..o n
............................andon.............
.......at...................
served it on the within named.............
by delivering a copy to h.... and tendering to h.... the fee for one day's attendance and the mileage allowed by law.'
Da ted........................ I 9...
B Y..............
Service Fees Tra vel................. 5 Services...
..........5 To tal................. $
Subscribed and sworn to before me. a...........................this........
da y o f.......................... I 9......
NOTE - Affidavit required only if service is made by a person other than a t;nited States Marshal or his deputy.
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Fors and murent nord not be tenderr t to the mornres upon seerser.*! e subrnene tuurd on behalt of the L:noted States or en officer or egents shares.r
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j, Schedule of Documents i
^
CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connection with the preparation of Supplemental Safety Evaluation Report No.
7, January 1985; No. 8, February 1985; No. 9, March 1985; No. 10, i
April 1985; and No. II,,May 1985.*
" Documents" include, but are not limited to, all drafts of the SSERs, interim or final reports, memoranda, notes, summaries, tapes, transcripts, interview reports, procedures, instructions, drawings, engineering analyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books, telephone messages, computer runoffs, and allegation tracking system computer runoffs generated during the SRT/TRT work related to this specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issues /
allegations raised in this SSER.
This request is similar to information already requested and being compiled in response to several Freedom of Information Act (FOIA) Requests from the Government Accountability Project.
When the information responsive to this subpoena duces tecum has been oroduced in response to the FOIA, CASE will accept a digest of the information with its location or production date and/or accession number.
(Those FOIA requests are 85-15, 19, 33, 34, 50, 59 and 299).
linitch 9tates of America NUCLEAR REGULATORY COMMISSION O
In the matter of:
' TEXAS UTILITIES GENERATING COMPANY.
et.al.
). DOCKET NO. 50-445-2 (Cotsanche Peak Steam Electric 50-446-2 Station, Units 1 and 2)
TO Mr. Herbert Livermore U.S. Nuclear Regulatory Commission Washington, D.C.
20555 YOU ARE HEREBY COMMANDED to appear..at.15.55... Connecticut.. Avenue, NW
.........S nite.. 20 2................
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in the city of... Washington... A C,..................................
on the...... 2.9....... day of...Q9.t.QDM..........I 9. 8.5.....a t............l..t.0,0. 0' clock P M.
to testify on behalf of... Citizens..Asociation..for.. Sound... Energy...(. CASE) in the above entitled action and bring with you the document (s) or object (s) descrit>ed in the attached schedule.
1 BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD BY Anthony Z Roisman, Esq.
ATTORNEY FOR MM
..... 19 =
2000 P Street, NW, f611 Hachingtnn.
n_C-20036~
mEPHONE ( 202 ) 463-8600 10 C.F.R. 2.720 (f) presidans officer or. if he is unvailable. the On motion made promptly, and in any ownt Commission may (1) quash or modify the sub-at or before the time specified in the nubpoena poena if it is unreasonable or requires evidence for compliance by the person to whom the sub-not relevant to any matter in issue. or (2) con-poena is directed. and on nottce to the party at dition denial of the motion on just and reasonable menose instance the subpoena was issued the term s.
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RETURN ON SERVICE l
Received this subpoena at.....
......o n
...............andon.....................at..................................
served it on the within named...............
by delisering a copy to h.... and tendering to h..... the fee for one day's attendance and the mileage allowed by law.'
D a t ed......................... I 9......
BY...
Service Fees Travel....
..........5 Services................... $
To tal.................. 5 Subscribed and sw orn to before me, a..................this...................
da y o f...................
... I 9.....
NOTE - Affidavit required only if service is made by a person other than a United States Marshal or his deputy.
I fees and miseere need not be tendere.1 to the s.ntness upon sen ere..! a subparna issued un behat!,,r the Untred States or an officer or agenes therect
- s tSC Isl3 l
Schedule of Documents CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connection with the preparation of supplemental Safety Evaluation Report No.
11, May 1985.*
" Documents" include, but are not limited to, all drafts of the SSERs, interim or final reports,. memoranda, notes, summaries, tapes, transcripts, interview reports, procedures, instructions, drawings, engineering analyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books, telephone messages, computer runoffs, and allegation tracking system computer runoffs generated during the SRT/TRT work related to this specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issues /
allegations raised in this SSER.
This request is similar to information already requested and being compiled in response to several Freedom of Information Act (FOIA) Requests from the Government Accountability Project.
When the information responsive to this subpoena duces tecum has been produced in response to the FOIA, CASE will accept a digest of the information with its location or production date and/or accession number.
(Those FOIA requests are 85-15, 19, 33, 34, 50, 59 and 299).
t Enitch 9tates of America NUCLEAR REGULATORY COMMISSION C
In the matter of:
TEXAS UTILITIES GENERATING COMPANY, et.al.
(Comanche Peak Steam Electric
> DOCKET NO.
50-- 445-1 Station, Units 1 and 2) 50 - 446-2 TO Nr. Jose Ct.lvo U.S. Nuclear Regulatry Commission Washington, D.C.
20555 YOU ARE HEREBY COMMANDED to appear.....at.15t55...Connectient..Ava,., NW
.....Suitn.2A2............................................................................
in the ci ty o f..........Mashington,... D.C............................................................
on the.... 39....... day of.......Qs.t.9be.K........19.R 5..
..a t.........D.Q Q.. 0' clock A M.
to testify on behalf of.... Citizens...Aasocia. tion...for... Sound.. Energy...ICASE) i l
in the above entitled action and bring with you the document (s) or object (s) described in the z.ttached schedule.
6 l
i BY ORDER OF TiiE ATOMIC SAFFTY AND LICENSING BOARD l
BY Anthony Z. Roisman, Esq.
ATTORNEY FOR NR
_ _19.-.
onnn o c+r..*; m.
- 611
'"rdir;ter, D C.
20036 TELEPHOy; (202) 463-8600 i
I I
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presiding ofjscer or, if he is envalubte. the On motion made promptly. and in any ownt Commission may (I) quash or modify the sub-at or before the time specified in the habpoena poena if it is unreasonable or requires evidence for compliance by the person to whom the sub-not relevant to any matter in issue. or (Lt con-poena is directed, and on notice to the party at ditton denial of the motion on just and rea.conable dose instance the subpoena ws sssued. the terms.
RETURN ON SERVICE Received this subpoena at......
...o n
......and o n.....
......a t..
served it on the within named..........
by delivering a copy to h..
and tendering to h....
the fee for one day's attendance and the mileage allowed by law.'
Da t ed.............
.. 19..
B Y..........
Service Fees Travel......
..........5 Services............. $
To tal.....
........ 5 Subscribed and sworn to before me, a..................th is.......
day of......
... 19..
NOTE - Af*idavit required only if service is made by a person other than a United States Marshal or his deputy.
I Fres and mileste need not be tendere.I to the s.stness urun serner..! a suhrnena issued in behalf out the United States or en officer or agency therro!
. CSC l '.'.1
Schedule of Documents CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connection with the preparation of Supplemental Safety Evaluation Report No.
7, January 1985.*
" Documents" include, but are not limited to, all drafts of the SSERs, interim or final reports, memoranda, notes, summaries, tapes, transcripts, interview reports, procedures, instructions, drawings, engineering analyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books, telephone messages, computer runoffs, and allegation i
tracking system computer runoffs generated during the SRT/TRT l
work related to this specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issues /
allegations raised in this SSCR.
F
'This request is similar to information already requested and l
being compiled in response to several Freedom of Information Act (FOIA) Requests from the Government Accountability Project. 1(h' n e
the information responsive to this subpoena duces tecum has been produced in response to the FOIA, CASE will accept a digest of the information with its location or production date i
and/or accession number.
(Those FOIA requests are 85-15, 19, 33, 34, 50, 59 and 299).
l t
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t
hitch 9tates of America NUCLEAR REGULATORY COMMISSION C
In the matter of:
TEXAS UTILITIES GENERATING COMPANY, et.al.
> DOCKET NO.
-445-2 (Comanche Peak Steam Electric Station, Units 1 and 2)
TO Mr. Conrad McKracken' U.S. Nuclear Regulatory Commission I
Washington, D.C.
20555 YOU ARE HEREBY COMMANDED to appear.1555.. Connecticut..Av.enue....NW,
.......Snite.202............................................................................................
m the city of....W.s,tli ng,t,g p.,,,, p.,,p,,,,,,,,,
on the....... 3.Q..... day of....... october........191L5......a t.............l.t.0 a.0' dock P M.
to testify on behalf of.Ci.tiACDA..harS.QCiation...foI.. Sound... Energy...(. CASE) in the above entitled action and bring with you the document (s) or object (s) described l
in the attached schedule.
Il' BY ORDER OF THE ATOMIC SAFETY AND UCENSING BOARD l
BY l'
Anthony Z. Roisman, Esq.
ATIORNEY POR r 0;=
....,19...,.....
2000 P St..MW Wanhington.
D.C.
20016 (202) 463-8600 11ELEPHONE l
l 10 C.F.R. 2.720 (t) pressding orjuer or. if he is unvensabte. the On motion made promptly, and in any event Commission may (1) qua* or unodify the sub-et or befort the time specified gn the a.bpoena poena if it is unrrssonable or requires evidence l
for compliance by the person to whom the sub-not relevent to any matter he i.anut. or (2) con-l poena is directed. and on notice to the party et dition denuni of the monon on just and ressonable J
Most intrance the subpcene was issued. the terms.
l
RETURN ON SERV!CE
..o n Received this subpoena at.....
.......and o n.....
....at.....................
served it on the within named....
by delivering a copy. to h.... and tendering to h..... the fee for one day's attendance and the mileage allowed by law.'
Da t ed...................... I 9.....
B Y....
Service Fees Travel............... 5 Services.................
5 f
To tai...................... $
n 4
-j Subscribed and sw orn to before me, a.........................this....................
5 day of........
......................I9......
NOTE - Affidavit required only if service is made by a person other than a United States Marshal or his deputy.
l I fees and naileert need not be tendered to the mirness upon semer..! e suhrena tsrued an behery of the t'nited States or en officer or agency thereof
- s U$l' I w.1 t
Schedule of Documents CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connect. ion with the preparation of Supplemental Safety Evaluation Report No.
9, March 1985.*
" Documents" include, but are not limited to, all drafts of the SSERs, interim or final reports, me moranda, notes, summaries, tapes, transcripts, interview reports, procedures, instructions, drawings, engineering analyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books,. telephone messages, computer runoffs, and allegation tracking system computer runof fs generated during the SRT/TRT work related to this. specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issuen/
allegations raised in this SSER.
This request is similar to information already requested and being compiled in response to several Freedom of Information Act (FOIA) Requests from the Government Accountability Project.
When the information responsive to this subpoena duces tecum has been produced in response to the FOIA, CASE will accept a digest of the information with its location or production date and/or accession number.
(Those FOIA requests are 85-15, 19, 33, 34, 50, 59 and 299).
Enitch 9tates of America NUCLEAR REGULATORY COMMISSION
.v l
In the matter of:
TEXAS UTILITIES GENERATING COMPANY, et.al.
> DOCKET NO.
50-445-2 (Comanche Peak Steam Electric 50-446-2 Station, Units 1 and 2)
TO Mr. Richard Bangert O.S. Nuclear Regula. tory Commission Washington, D.C.
20555 YOU ARE HEREBY COMMANDED to appear at..15.55... Connecticut.. Avenue, NW
....S..u...i..t..e...2.0.2...............................................................................................................
m the city of....Was 11ingt an o...D..C.........................................................................
on the........ 34.....da3 of. october.............I 9. 8 5.....at............. 3+0 0 0' clock p M.
to testify on behalf of. Citizens.. Association...for.. Sound... Energy...(CASE) in the above entitled action and bring with you the document (s) or object (s) described in the attached schedule.
~.
BY ORDER OF THE ATOMIC SAFETY AND UCENSING BOARD BY l
i NE
.19..
ATTORNEY POR Anthnnu 7 Dnieman_ Rgg, c.2ite 611' onnn n c.
sn.:
M hingt:, D.C.
20036 TEtJJHONE f2021 l
10 C.F.R. 2.720 (f) prendent officer er. sf he is un=s.ble. she On motion made promptly. and in any ownt Commission may U) quash or modify ake sub-I et or before she time spectfkd in the asbpoena porne if it is unreesonable or requires endence l
for compliance by the person to whom the sub-not relement to any matter in innue, or (2) con-I poene is dsrected. and on notice to the party at dition denial of the motion on just and reasonable dose instance the subpoena ws issued. the terms.
RETURN ON SERVICE 1
l
..o n Received this subpoena at....
...........................a nd o n....
......a t.......
served it on the within named............
by delivering a copy to h.... and tendering to h... the fee for one day's attendance and the mileage allowed by law.'
Da ted..............
I 9.....
BY......................................
Service Fees Trn vel.................... 5 Services.................. 5 t.
i To ta l....................... 5 l
s Subscribed and sworn to before rne, a........................this.............
i do y o f................................... I 9..
NOTE - Affulavit required only if service is made by a person other than a United States Marshal or his deputy.
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i fees and miJeare need not be tenderra to the mitnent urun serwe **! a suhrmena issued in benety of the j
l t nited Santes or en officer or agency skerect
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i er
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v Schedule of Documents CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connection with the preparation of Supplemental Safety Evaluation Report No.
8, February 1985.*
" Documents" include, but are not limited to, all drafts of the SSERs, interim or final reports, memoranda, notes, summaries, tapes, transcripts,-interview reports, procedures, instructions, drawings, engineering analyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books, telephone messages, computer runoffs, and allegation tracking system computer runoffs generated during the SRT/TRT work related to this specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issues /
allegations raised in this SSER.
0 This request is similar to information already requested and being compiled in response to several Freedom of Information Act (FAIA) Requests from the Government Accountability Project.
When the information responsive to this subpoena duces tecum has been produced in response to the FOIA, CASE will accept a digest of the information with its location or production date and/or accession number.
(Those FOIA requests are 85-15, 19, 33, 34, 50, 59 and 299).
l
Enitch 9tates of America NUCLEAR REGULATORY COMMISSION C
i In the matter of:
TEXAS UTILITIES GENERATING l DOCKET NO.
COMPANY, et. al.
5 45 (Comanche Peak Steam Electric Station, Units 1 and 2)
TO Mr. Larry Shao U.S. Nuclear Regulatory Commission Washington, D.C.
20555 YOU ARE HEREBY COMMANDED to appear......a.t...A.5.M...C9.UD9.9tiGMt..Aygnpe, N.W.
... Suite..2A2....................
in the ci ty o f...Ma sh i ng ton..... D.,.C................................................................
on the.... 31......... day o f....DctobeI..........19.8 5......a t.....b.00..... 0' clock A M.
to testify on behalf of.... Citizens... Association...for..Snund.. Energy...lCASE) in the above entitled action and bring with you the document (s) or object (s) described in the attached schedule.
4 BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD l
BY Anthony Z. Roisman,,Esq.
ATTORNEY FOR PAM
- ,19; gnnn n c +.
mar.r
::hing =, D.C.
(202) 463-8600 TELEPHONE 10 C.F.R. 2.120 (f) presidins otticer or, it he is unvattable. the On motion made promptly, and in any twnt Commission may (1, quash or modify the sub-.
at or before the time specified in the subpoer.*
poena if it is unreasonable or requires evidence for compfbance by the person to whom the sub-not relevant to any matter tre issue, or (2) con-poena is directed, and on notice to the party at ditton denial of the motion on just and reasonable dose instance the subpoena was issued. the terms.
RETURN ON SERVICE Received this subpoena at......
....o n
..and on...
..............at........
served it on the within named....
by delivering a copy to h.... and tendering to h... the fee for one day's attendance and the mileage allowed by law.'
Dated....
....... I 9......
BY.............
Service Fees Trsvel....
..... 5 Services....
.........5 To tal...............
5 Subscribed and sworn to before me, a...............t h is..........
day of..
...... 1 9.....
NOTE - Affidavit required only if service is made by a person other than a United States Marshal or *1is deputy.
i i
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,,g,,,,,,,4,,, y,,,,g,,,,,,,,u,,,,,,,,,p,,,,,,,,,,,y,,, p p,,,,
,,,,,4
,, y,,,,, vy,g, t nited States or an officer or agenes thereor
.% ( SC I s2.9
Schedule of Dccuments CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connection with the preparation of Supplemental Safety Evaluation Report No.
10, April 1985.*
4
" Documents" include, but are not limited to, all drafts of the SSERs, interim or final reports, memoranda, notes, summaries, tapes, transcripts, interview reports, procedures, instructions, drawings, engineering enalyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books, telephone messages, computer runoffs, and allegation tracking system computer runoffs generated during the SRT/TRT work related to this specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issues /
allegations raised in this SSER.
.(
This request is similar to information already requested and being compiled in response to several Freedom of Information Act (FOIA) Requests from the Government Accountability Project.
When p
the information responsive to this subpoena duces tecum has been produced in response to the FOIA, CASE will accept a digest of the information with its location or production date and/or accession number.
(Those FOIA requests are 85-15, 19, 33,
~
34, 50, 59 and 299).
l y,,
Eniteb Btates of America L
o, NUCLEAR REGULATORY COMMISSION O
In the matter of:
TEXAS UTILTIES GENERATING COMPANY, et.al.
e,0-445-2 (Comanche Peak Steam Electric
> DOCKET NO.
50-446-2 Station, Units 1 and 2)
TO Mr. Thomas Ippilito U.S. Nuclear Regulatory Commission Washington, D.C.
20555 YOU ARE HEREBY COMMANDED to appear...1555.. connect.i-aut..Avenuey NW,
....S.ui$c.202.........................................................................................................
in the city o f......WA.S.hi.RgAQ D.e...D.,.C...........................................................................
on the..... 31........ day of.... 0ctnber..........198.5........a t........... 3.:.0a.0' clock P M.
to testify on behalf of..... Citizens...Associatinn...for.. Sound... Energy...(. CASE) in the above entitled action ano bring with you the document (s) or object (s) described in the attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD BY Anthony Z.
Roissan, Esq.
m0RNEi POR
-'g,=
g 2000 P Street, NW Suite 611 Washinoton.
D.C.
20036 (202) 463-8600 TELEPHONE 10 C.F.R. 2.120 (t) pressdens orncer or. of he is un,annable, she l
On motion made promptly, and in any ownt Commismon may (I) quash or modify she sub-at or before she time spectfled in the subpoena poena if it is unnssonable or requkes esternce for compliance by the person to whom the sub-not Nievent to any matter be tanue or (2) con-poena is directed, and on notice to the parry at dition denial of the morson on just and reasonable smhose instance she subpoena sees innued. the terms.
RETURN ON SERVICE
..o n Received this subpoena at..
......................a nd o n.............
.....at.............
served it on the within named...
by delivering a copy to h.... and tendering to h... the fee for one day's attendance and the mil cage allowed by law.'
Da ted.................. I 9....
BY....................................~......
Service Fees Tra vel................. 5 Services................ $
g:
To ta l....................... 5 Subscribed and sworn to before me, a.........................this.......................
I da y of....
....................... ! 9.......
NOTE - Affidavit required only if service is made by a pmon other than a United States Marshal or his deputy.
h-I Fees en1 mikare need nat be tenderra to the witness upon semer.f a suhtwna issued m behelp of the g'
-(*nited $setts or en officer or egency thereof
.s l'5C' I Q.$
1
t Schedule of Documents i
CASE requests that the deponent bring with him to the deposition all documents or documentation generated in connection with the preparation of the July 13, 1984 letter from Darrell Eisenhut to Michael D. Spence, with the report of the Special Review Team j
i inspection.
" Documents" include, but are not limited to, all drafts nf the SSERs, interim or final reports, me moranda, notes, summaries, tapes, transcripts, interview reports, procedures, instructions, drawings, engineering analyses, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, notebooks, books, telephone messages, computer runoffs,,and allegation tracking system computer runoffs generated during the SRT/TRT work related to this specific SSER, or other Staff work which served as a basis for any Staff conclusion on the issues /
I allegations raised in this SSER.
e i
l
[
i i
This request is similar to information already requested and being compiled in response to several Freedom of Information Act (FOIA) Requests from the Government Accountability Project.
When the information responsive to this subpoena duces tecum has been produced in response to the FOIA, CASE will accept a digest of the information with its location or production date and/or accession number.
(Those FOIA requests are 85-15, 19, 33, 34, 50, 59 and 299).
l l
a'
. _.