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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] Category:PLEADINGS
MONTHYEARML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A6131993-01-0707 January 1993 Motion for Leave to File Out of Time & Request for Extension of Time to File Brief.* Petitioners Did Not Receive Order in Time to Appeal & Requests 15 Day Extension from Motion Filing Date to Respond.W/Certificate of Svc ML20127A7911992-12-31031 December 1992 Petitioner Amended Motion for Continuance to File Appeal Brief.* Petitioners Requests Until C.O.B. on 930108 to File Appeal Brief.W/Certificate of Svc ML20127A7641992-12-30030 December 1992 Petitioner Motion for Continuance to File Appeal Brief.* Counsel Requests That Petitioners Be Granted Until 930109 to File Brief in Support of Notice of Appeal.W/Certificate of Svc ML20128C9751992-12-0303 December 1992 NRC Staff Response to Motion to Compel Disclosure of Info Secreted by Restrictive Agreements & Notification of Addl Evidence Supporting Petition to Intervene by B Orr,D Orr, J Macktal & Hasan.* W/Certificate of Svc ML20128B8721992-11-27027 November 1992 NRC Staff Response to Motion for Rehearing by RM Dow, Petitioner.* Motion for Rehearing Should Be Denied for Reasons Explained in Encl.W/Certificate of Svc ML20128A0271992-11-25025 November 1992 Texas Utilities Electric Co Answer to Motion to Compel Disclosure of Info Secreted by Restrictive Agreements.* Util Requests That Petitioners 921118 Motion to Compel Be Denied in Entirety.Certificate of Svc Encl ML20127P8181992-11-25025 November 1992 Texas Utilities Electric Co Answer to Notification of Addl Evidence Supporting Petition to Intervene.* Petitioners Notification Procedurally Improper & Substantively Improper & Should Be Rejected by Board.W/Certificate of Svc ML20116M4591992-11-19019 November 1992 TU Electric Opposition to Motion for Rehearing by RM Dow.* RM Dow 921110 Motion for Rehearing Should Be Denied.W/ Certificate of Svc ML20127M4271992-11-15015 November 1992 Motion to Compel Disclosure of Info Secreted by Restrictive Agreements.* Petitioners Bi Orr,Di Orr,Jj Macktal & SMA Hasan Requests That Board Declare Null & Void Any & All Provisions in Settlement Agreements.W/Certificate of Svc ML20116M3181992-11-10010 November 1992 Motion for Prehearing by RM Dow,Petitioner.* Requests Period of Ten Days to File Supplemental Pleading to Original Petition.Certificate of Svc & Statement Encl ML20106D8881992-10-0808 October 1992 Opposition of Util to Motion for Extension of Time to File Brief by SL Dow Doing Business as Disposbale Workers of Plant & RM Dow.* Request for Extension of Time & to Become Party to Proceeding Should Be Rejected.W/Certificate of Svc ML20106D2821992-10-0505 October 1992 Motion for Extension of Time to File Brief by SL Dow Doing Business as Disposable Workers of Comanche Peak Steam Electric Station & RM Dow.* Petitioner Requests 30-day Extension.W/Certificate of Svc ML20101P5891992-06-30030 June 1992 Response of Texas Utils Electric to Comments of Cap Rock Electric Cooperative,Inc. Dispute Strictly Contractual Issue Involving Cap Rock Efforts to Annul Reasonable Notice Provisions of 1990 Power Supply Agreement ML20127K8141992-05-19019 May 1992 Request to Institute Proceeding to Modify,Suspend or Revoke License Held by Util for Unit 1 & for Cause Would Show Commission That Primary Place of Registration for Organization Is Fort Worth,Tarrant County,Tx ML20096A6281992-05-0707 May 1992 Applicants Reply to Opposition cross-motions for Summary Disposition & Responses to Applicants Motion for Summary Disposition.* Applicants Conclude NRC Has No Authority to Retain Antitrust Licensing Conditions.W/Certificate of Svc ML20095C4691992-04-17017 April 1992 TU Electric Answer to Application for Hearings & Oral Argument by M Dow & SL Dow.* Concludes That NRC Should Deny Application for Oral Argument & Hearings on Petition to Intervene & Motion to Reopen.W/Certificate of Svc ML20091E2561992-04-0606 April 1992 Application to Secretary for Hearings & Oral Argument in Support of Motion for Leave to Intervene out-of-time & Motion to Reopen Record Submitted by SL Dow Dba Disposable Workers of Comanche Peak Steam Electric Station & RM Dow.* ML20094K4161992-03-16016 March 1992 TU Electric Answer to Petition to Intervene & Motion & Supplemental Motion to Reopen by M Dow & SL Dow & TU Electric Request for Admonition of Dows.* Concludes That Motion Should Be Dismissed.W/Certificate of Svc ML20091A0461992-03-13013 March 1992 Suppl to Motion to Reopen Record.* Requests That NRC Reopen Record & Suspend License Pending New Hearings on Issue. W/Certificate of Svc ML20090C4241992-02-24024 February 1992 Motion to Reopen Record.* Requests That NRC Reopen Record & Suspend OL for Unit 1 & CP for Unit 2,pending Reopening & Final Decision.W/Certificate of Svc ML20090C4431992-02-21021 February 1992 Petition for Leave to Intervene Out of Time.* Requests That Petition for Leave to Intervene Out of Time Be Granted for Listed Reasons.W/Certificate of Svc ML20086Q3811991-12-26026 December 1991 Case Response to Portions of Motion of R Micky & Dow to Reopen Record.* Submits Responses to Motions to Reopen Record ML20086Q3121991-12-26026 December 1991 Case Motion for Leave to File Response to Portions of Motion of R Micky & Dow to Reopen Record.* Requests That NRC Recognize J Ellis as Case Representative for Filing & Pleading Purposes.W/Limited Notice of Appearance ML20091G2511991-12-0202 December 1991 Licensee Answer to Motion to Reopen Record by M Dow & SL Dow.* Requests That Petitioners Motion Be Denied for Listed Reasons.W/Certificate of Svc & Notices of Appearance ML20086G7381991-11-22022 November 1991 Motion to Reopen Record.* Requests That Licensing Board Reopen Record & Grant Leave to File Motion to Intervene. W/Certificate of Svc ML20006C4811990-02-0101 February 1990 Applicant Answer to Request for Stay by Citizens for Fair Util Regulation (Cfur).* Cfur Failed to Satisfy Burden to Demonstrate Necessity for Stay & Request Should Be Denied. Certificate of Svc Encl ML20006B1691990-01-27027 January 1990 Second Request for Stay Citizens for Fail Util Regulation.* Requests That NRC Stay Fuel Loading & Low Power Operation of Unit 1 Until 900209.Certificate of Svc Encl ML20248J3601989-10-15015 October 1989 Request for Stay Citizens for Fair Util Regulation.* Requests That Commission Retain Authority to Order That Fuel Loading & Low Power License Not Be Immediately Effective,Per Util Intent to Request License.Certificate of Svc Encl ML20246B8671989-08-17017 August 1989 Motion for Reconsideration of NRC Memorandum & Order CLI-89-14.* NRC Should Excuse Itself from Consideration on Matters Re Jj Macktal & Should Refer All Issues on NRC Requested Subpoena to Independent Adjudicatory Body ML20248D6291989-08-0202 August 1989 Jj Macktal Statement Re Motion for Recusation.* Macktal Motion Considered Moot Due to Commission No Longer Having Jurisdiction to Consider Motion Since Macktal Not Party to Proceeding Before Nrc.W/Certificate of Svc ML20247Q3851989-07-26026 July 1989 Withdrawal of Motion to Reopen Record.* Withdraws 890714 Motion to Reopen Record.W/Certificate of Svc ML20245J7331989-07-26026 July 1989 Request of Cap Rock for Reevaluation of Director'S Determination That No Significant Changes in Licensee Activity Warrant Antitrust Review at OL Stage.Certificate of Svc Encl ML20247B5901989-07-19019 July 1989 Motion to Reopen Record.* Requests Board to Reopen Record & Grant Leave to Renew Earlier Motion for Intervention Status. W/Supporting Documentation & Certificate of Svc ML20248D5731989-07-0303 July 1989 Motion for Reconsideration.* Requests Reconsideration of NRC 890122 Order on Basis That NRC Subpoena Filed for Improper Purposes & NRC Lacks Jurisdiction Over Matters Presently Before Dept of Labor ML20248D5541989-07-0303 July 1989 Motion for Recusation.* Requests That NRC Recuse from Deciding on Macktal Cases on Basis That NRC Will Not Be Fair & Impartial Tribunal.W/Certificate of Svc ML20245J9411989-06-30030 June 1989 Response of Texas Utils Electric Co to Request of Cap Rock Electric Cooperative,Inc,For Order Enforcing & Modifying Antitrust License Conditions ML20248D4891989-06-13013 June 1989 Motion for Protective Order.* Requests That Jj Macktal Deposition Be Taken at Stated Address in Washington,Dc & That Testimony Remain Confidential.W/Certificate of Svc ML20011E8571989-02-10010 February 1989 Reply of Cap Rock Electric Cooperative,Inc to Comments of Texas Utils Electric Co.* Texas Utils Response Considered Irrelevant,Mainly Incorrect or Misleading.Certificate of Svc Encl ML20155A8251988-10-0303 October 1988 NRC Staff Response to Citizens for Fair Util Regulation First Suppl to Request for Hearing & Petition for Leave to Intervene.* Petition & Requests for Hearings Should Be Denied.W/Certificate of Svc ML20154Q2021988-09-28028 September 1988 Applicant Reply to Citizens for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur Request Should Be Denied. Certificate of Svc Encl ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20151A6181988-07-12012 July 1988 Motion for Petitioners to Appear Pro Se.* Petitioners Request to Appear Before Board at 880713 Hearing in Order to Present Arguments in Support of Petitioners Motions & for Stay of Proceedings.W/Certificate of Svc ML20150E1831988-07-12012 July 1988 Response of Applicant to Motions to Stay,To Intervene & for Sua Sponte Relief Filed by Various Petitioners.* Papers Filed by Petitioners Should Be Rejected & Denied & Dismissal of Proceedings Be Completed.W/Certificate of Svc 1993-03-19
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Septemy g p 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 85 SEP -6 A'0 29 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In thh Matter of )
)
TEXAS UTILITIES GENERATING ) Docket Nos. 50-445-2 COMPANY, et al. ) and 50-446-2
)
(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
CASE'S REQUZST FOR DOCUMENT PRODUCTION Pursuant to 10 CFR 2.741, CASE requests that Applicant produce the following documents for inspection a'hd copying in the manner set forth below:
1). Each document should include all pertinent information known to Applicant, their officers, directors, or employees, their agents, advisors, or counsel. This request is to include all CPRT/SRT documents.
The term " employees" is to be construed in the broad sense of the word, including specifically (but not limited to): Texas Utilities,, et. al. Brown & Root, Gibbs & Hill, Ebasco, Cygna, 0.B. Cannon, Cresap, McCormick and Paget, any consultants or subcontractors, and anyone else performing work or services on
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behalf of the Applicants or their agents or subcontractors and ,
anyone else performing work or services on behalf of the Applicants or their agents or subcontractors. The term employee 8509090298 850904 PDR ADOCK 05000445 g PDR
r V
refers to all employees performing work for the Applicant, whether or not the Applicant intends to rely upon the information in meeting its regulatory requirements.
2). The terms " documents" and "documen tat ion " shall be constgued in the broad sense of the words and shall include any and all writings, graphs, charts, photographs, reports studies, audits, microfiche, slides, internal memoranda, informal notes, handwritten notes, tape recordings, procedues, specifications, calculations, analyses and any other data conpilations, from which information can be obtained, including printouts of any and all such information which is contained on computer discs or in computerized files or similar files.
The term " documents" shall also include any and all contracts, letters of understanding, letters of intent, purchase orders, statement of protocol, statement of scope, any and all other related or similar documents, and all other pertinent
! information.
I i
The term " documents" or " documentation" shall also include any and all minutes of meetings, meeting summaries, meeting agendas, briefing papers or any other similar documentation, any and all other related or similar documents, and all other pertinent information.
3). For each item supplied in response to a request for documents, indentify the specific question number to which i,t is in response.
4). References to corporations herein also refer to individuals. References to corporations by name include all l
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e
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parents or subsidiaries of the Applicant, as well as all the minority owners of Comanche Peak.
REQUEST I
! 1. Management and job responsibility changes.
I a. All internal documents relating to the structure of key management changes at Comanche Peak beginning January 1, 1979 i
until present including minutes of all meetings, minutes of i briefings of the Board of Directors, the CEO, and other owners of i
j Comanche Peak.
1 I b. All internal documents reflecting the actual changes in #
l 1 management at Comanche Peak, the basis for those changes, and the i
4 justification of those changes given to the individuals involved L including minutes of all meetings, minutes of briefings of the 1
! Board of Directors, the CEO, other owners of Comanche Peak; all i
the written explanations provided to the individuals removed, l
1 transferred, demoted, reassigned, or in any other way af fected by management changes.
4
- c. All notes of conversations or summaries or descriptions l
of conversations since January 1, 1979 between NRC officials recommending or suggesting any management changes,.or any l.
i dissatisfaction with specific individuals performance or the attitude of management in general.
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{ d. A complete, up-to-date list, including'an organizational I
l chart for all contract and sub-contract personnel now doing work on design and/or construction of the Comanche Peak Nuclear Plant.
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l 1
l L , _ _ _ . - - . . _ _ _ . - _ _ . - _ _ , _ -
t
_4_
This should be comprehensive to first line supervisors in both construction and quality assurance / quality control, whether or not the work will be relied upon to meet regulatory requirements.
- e. A complete, up-to-date list of the present job of any person who was a witness for Brown & Root or Texas Utilities Company in NRC operating license hearings or Department of Labor wrongful termination procedings if, at the time they testified, were deposed, or provided affidavits, they worked for any of the Applicants (i.e. owners or contractors) or with subcontractors or consultants at the plant.
- f. All documentation, including contracts between Texas Utilities and any other company, setting forth the agreements which govern or control the assignment parameters of all individuals identified in items a through f.
- g. The job evaluations, performance ratings, letters of recommendation or, if appropriate, letters of resignation, and any other documents relevant to all personnel changes identified j , in Items a and c. Where no such document exists but the substance of an evaluation, or the basis for a resignation or i
termination (transfer, etc.) was provided in the context of a l meeting, provide all minutes or notes of those meetings.
- h. In addition to Items a-g for any other Applicant witness who has given testimony, depositions, or affidavits, in the proceedings identified in section e above, iden'tify any job or responsibility change and provide all documents relevant to the reason for and nature of the change.
I i
O
- i. For each personnel change identified in any of the above responses provide the new job description, or memorandum of instructions, detailing the scope of responsibility and authority to each individual. Also included in this item is any memor,andum, 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.
- j. Any other document which bears on the overall personnel i
and management changes from January 1, 1979 to present.
- 2. Contracting documents.
All contracting documents between any of the Comanche Peak ,
owners, themselves and other auditing, consulting, construction, or any other type of company related to construction of Comanche Peak.
- 3. Speeches to workforce regarding organization and management
- a. Provide copies or notes of all speeches given by Texas' Utilities or Brown and Root management personnel to the Comar.che Peak workforce (or any group thereof), since January 1, 1979, including quality assurance / quality control, regarding
- organizational or management changes at Comanche Peak, including
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but not limited to Mr. Spence's March / April 1985 speeches to the
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QC inspectors about the problems and status of the plant. .
! b. For each communication provide the written record of
! that communication, any transcripts or notices of speeches or meetings, and all written records of the results of those communications.
b
- 4. Documents provided to work force.
- a. All documents and/or other information provided to employees at any time regarding plant safety (not worker safety),
federal regulations, and procedures for reporting plant safety violations or dificiencies.
- 5. Documents regarding status and 1icensing of plant.
- a. All documents provided to the owners or stockholders of the owners which detail the status of the plant, problems at the plant, the status of licensing, and the changes being made to i
address those problems.
- b. All documents provided ,at meetings and documents of meetings betw'een owners, stockholders, investors, investments advisore, bankers or similar persons who have money invested in CPSES or are being encourage to invest in CPSES which provide explanations about the status of licensing, problems at the plant, status of the plant, or management changes.
- c. All documents regarding scheduling and projections for construction including completion dates for Comanche Peak Units 1 and 2 or portions thereof provided to or developed for the NRC Caseload Forecast Panel, the Board of Directors of each of the Comanche Peak Owners, the Security Exchange Commission, Stockholders Meetings, outside consultants, or Public Utilities Commission of the State of Texas.
- d. All documents relating to the cost of correcting ,
deficiencies in safety, construction, or design at Comanche Peak as well as costs of CYGNA audits (all phases), the Lobbin Report, the MAC Reports, the EBASCO audit, the INFO Audit, Southern i
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Engineering Audits, Analyses, Evaluations or Reports, and damage studies, Stone and Webster redesign and analysis work, and any i other audits, analysis, reports, evaluations of safety, ccnstruction, or design at Comanche Peak.
- 6. SAFETEAM documents.
- a. All documents which relate to the basis for the removal or elimination of the ombudsman position, and any documents which recommend, justify, announce and or explain the replacement of the ombudsman program with the SAFETEAM.
- b. The contracts and agreements about the scope of work between the SAFETEAM and Texas Utilities Company and/or Brown'and Root, Inc.
- c. All written information regarding how the SAFETEAM implements its program; methodology, instructions, training materials, forms used in interviews, interview checklists, etc.
- d. All material developed by the SAFETEAM about allegations of harrassment, intimidation, threats or influence from any workers including allegations classified as regarding undesirable work conditions, safety problems and employee pay issues.
- 7. Status of licensing and scheduling documents.
- a. 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.
/
-a_
- b. All documents provided to, including all written records of personnel 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.
- c. 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 Park.
- d. All documents provided to, including all written records of personal or telephonic communication or meetings with, Senator Thomas Bevill, Congressman Morris Udall, Congressman James I
j 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.
- e. All documents provided to, including all written records of personal or telephonic communication or meetings with, Victor Stello and/or Harold Denton about the status of licensing, the hearings, and the status of the construction of Comanche Peak.
- f. All documents provided to, including all written records of personal or telephonic communication or meetings with William Dircks about the status of licensing, the hearings, and the status of the construction of Comanche Peak. l 1
l l
1
_9-All documents provided to, including all written records A
g.
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 he,arings, proposed site visitations, and the status of the construction of Comanche Peak.
- 8. TRT evaluations.
- a. All documentation prepared by, or for, or under the control of the CPRT or CPSES that relates to review of the TRT findings, beginning with any such documents generated in response to the September, 1984 letter from the TRT to TUEC on electrical problems, and including the October, 1984, November, 1984 and Janucry 11, 1985 letters, and the subsequently issued SSER Nos.
7, 8, 9,-10 and 11 this includes 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 all the TRT findings.
- 9. CYGNA documents re: QA/QC program.
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's finding that the cause of the design review problem was with the reviewers, not the procedures, but couldn't explain why the reivewers, weren't doing their job), or CYGNA's inability to determine why the design document control system broke down.
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- 10. Contractor information.
- a. All documentation, including contracts between Comanche Peak Owners or other subcontractors (such as EBASCO) which defines the scope of the assignments of contract personnel who have been retained by the owner or any one of them 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.
- g. The contract and all other documents related to the scope of responsibility of any other independent contractor and/or consultant at Comanche Peak.
- h. All documentation that explains the relationship between all of the subcontractors identified in response to any question above and Comanche Peak Owners.
- 11. Scheduling forecasts.
All documents which contain scheduling forecasts for implementation of any reinspection or corrective action program which were provided to outside consultants, the Securities Exchange Commission, the Department of Energy, and 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.
- 12. MAC Report
- a. Copies of all contracts between MAC and Applicant or any of its subcontractors, beginning in 1976.
- b. Copies of all documents reports, audits, analysis, letters, correspondance, etc. provided by MAC to Applicant or any of its contractors beginning in 1976.
These include copies of the MAC audits of Brown and Root QA Program referred to in BN 85-076, Aug 16,1976.
- c. The notes, records, logs, memorandums of Mr. Andrew S.
Jones, senior auditor of TUSI.
- d. Produce and identify all other "outside perspectives",
which TUGCO or any of its managers received on Comanche Peak, regardless of whether or not TUGCO intended to rely upon the review to meet NRC regulatory requirements.
- 13. T-Shirt Incident / Electrical QA/QC .
Produce all documents developed since 1 July 1984 regarding
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the T-Shirt incident, or the Post Construction Verification Task Force, including any further investigations into destructive l
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n examinations, or an explanation for the lack thereof. Include l any review of the implications of the T-shirt incident on the workforce.
- 14. Liner Plate /QA/OC
- a. Produce the results and all bases of the TUEC investigation / inspection into the liner plate documention breakdown announced in December 1984 during the testimony of C.
Thomas Brandt.
- b. Produce all documents developed since 1 July 1984 regarding the liner plate OA/QC breakdown.
- 15. Paint Coatings /OA/OC
- a. Produce all documents related to the analysis of the paint coatings /QA/QC program, and the failure of the paint coatings OA/QC program to detect programmatic deficiencies.
- b. Produce all documents related to the analysis of the OA/QC management, including but not limited to the handling of the concerns of Messrs. Bill Dunham, Bob Hamilton, and Cory Allen.
- 16. Harassment and Intimidation
- a. Produce all documents which detail the disposition of the allegations of harassment and intimidation of both craft and QC personnel.
- b. Update all past discovery requests (re: harassment and intimidation) to include the same information for craft personnel (including but not limited to documentation personnel).
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- c. Produce all documentation which analyzes the harassment and itttimidation concerns of any worker for management (CPRT or CPSES).
Pursuant to 10 C.F.R. 2.741( d) answers to this document requegt must be provided within 30 days of the date of receipt of this pleading.
\W BILLIE PIRNER GARDE Trial Lawyers for Public Justice 2000 P Street, N.W., Suite 611 Washington, D.C. 20036 (202) 463-8600 Counsel for CASE l
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