ML20136J455

Response to Case 850729 Interrogatory.Interviews W/Review Teams & Personnel Indicate No Communications,Site Visits or Documentation from Util Re Review Team.Certificate of Svc Encl.Related Correspondence

ML20136J455
Person / Time
Site:	Comanche Peak
Issue date:	08/19/1985
From:	Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
CON-#385-277, CON-#385-316 OL-2, NUDOCS 8508200717
Download: ML20136J455 (5)

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m9 AEL4TED COHRh August 19, 1985 UNITED STATES OF AMERICA 'S hC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA $ A% 20 Ap ap CFFtc5c:uh,y.l OhE Tit Gj In the Matter of ) 3RANC4

) Docket Nos. 50-445-2 and TEXAS UTILITIES ELECTRIC ) 50-446-2 COMPANY, ET AL. )

) (Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

APPLICANTS' RESPONSE TO CASE INTERROGATORIES REGARDING THE CPRT Pursuant to 10 C.F.R. 52.740b, Texas Utilities Generating Company, et al. (" Applicants"), hereby respond to CASE's July 29, 1985, interrogatories regarding the CPRT.

APPLICANTS' RESPONSE CASE's interrogatories are, as follows:

1. Identify all communication, including site visitations, with Georgia Power Company regarding the development of the CPRT.g

2. Identify all documentation provided by Georgia Power Company to TUEC for consideration in the development of the CPRT program plan.

3. Identify all modules, procedures, implementing instructions, analysis models, reinspection programs, and any l

other materials which have been developed by Georgia Power Company in their Readiness Review Program, and which were supplied to TUEC in consideration of the development of the CPRT.

1/ Georgia Power Company refers to GPC or any of its contractors including subcontractors, consultants, I third party reviewers or co1sultants. .

I B508200717 850819 gDR ADOCK 05000445 l

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Applicants' interviewed members of the SRT and CPRT, to the Review Team Leader level, and CPSES project personnel to ascertain this information. (CPRT personnel are responsible for the development and implementation of the CPRT program.) To their knowledge, there have been no communications with, site visits by or documentation received from Georgia Power Company

< concerning the development of the CPRT or CPRT Program Plan.

Applicants provide the above information to assist in the l discovery process. However, Applicants consider these requests to be irrelevant. Even if material had been provided by Georgia i

Power Company, including material related to their " Readiness Review Program," it would have no bearing on issues in this proceeding.

Respectfully submitted, S

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Nicholas S.'Rdy'nolds William A. Horin BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9800

. Counsel for Applicants August 19, 1985 I

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l Terry C. Tyler, being first duly sworn deposes and says:

That he is employed by Energax /.Jeociates. Inc., and serves as the CPRT Program Director at Comanche Peak Steam Electric Station, and knows the contents of the foregoing Applicants' Response to CASE Interrogatories Regarding the CPRT, as designated therein, that the same is true of his own knowledge except as to matters therein stated on information and belief, and as to that he believes them to be true.

fi 1 ( 4 s ) M ). M Yetfy'C.~ ler State of YewAJ County of Soe m et<

A subscribed and sworn to before me this /9-day of August, 1985.

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poy comme s sres w erAes W <ros.2s,off$  !

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0 UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of )

) Docket Nos. 50-445-2, TEXAS UTILITIES ELECTRIC ) 50-446-2 l

COMPANY, ET AL. )

! ) (Application for l (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

l j CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to CASE Interrogatories Regarding the CPRT" in the above-captioned matter l were served upon the following persons by deposit in the United l

States mail, first class, postage prepaid on the 19th day of August, 1985.

Peter B. Bloch, Esquire Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Appeal Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission

( Washington, D.C. 20555 Washington, D.C. 20555 l Dr. Walter H. Jordan William L. Clements 881 West Outer Drive Docketing and Service Oak Ridge, Tennessee 37830 ' Branch U.S. Nuclear Regulatory Dr. Kenneth A. McCollom Commission Dean, Division of Washington, D.C. 20555 Engineering, Architecture l and Technology Stuart A. Treby, Esquire Oklahoma State University Office of.the Executive Stillwater, Oklahoma 74074 Director U.S. Nuclear Regulatory l Commission .

Washington, D.C. 20555'

)

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i

e i l l Chairman, Atomic Safety Geary S. Mizuno, Esq.

I and Licensing Board . Office of Executive Legal Panel Director l U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 7

$* Renea Hicks, Esquire Anthony 2. Roisman, Esquire Assistant Attorney General Trial Lawyers for Public

~; Environmental Protection Justice Division 2000 P Street, N.W. '

P.O. Box 12548 Suite 611 Capitol Station Washington, D.C. 20036 Austin, Texas 78711 Mrs. Juanita Ellis Lanny A. Sinkin President, CASE 3022 Porter Street j 1426 South Polk Street Suite 304

Dallas, Texas 75224 Washington, D.C. 20008

! Ms. Billie P. Garde Joseph Gallo, Esquire 4

Citizens Clinic Director Isham, Lincoln & Beale Government Accountability Suite 840 Project 1120 Connecticut Avenue, N.W.

i 1555 Connecticut Avenue, N.W. Washington, D.C. 20036 Suite 202 Washington, D.C. 20036 i

j Herbert Grossman, Esquire Ellen Ginsberg, Esquire Alternative Chairman Atomic Safety and Licensing l Atomic Safety and Licensing Board'

! Board U.S. Nuclear Regulatory

. U.S. Nuclear Regulatory Commission l Commission Washington, D.C. 20555 Washington, D.C. 20555 l

l Mr. James E. Cummins t

Resident Inspector / Comanche Peak Steam Electric Station c/o U.S. Nuclear Regulatory Commission P.O. Box 38

, Glen Rose, Texas 76043 f ,

~

William A. Horin l

cc: John W. Beck Robert A. Wooldridge, Esq.

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