ML20137M107
| ML20137M107 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/27/1985 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#485-368 OL, NUDOCS 8512030615 | |
| Download: ML20137M107 (6) | |
Text
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Filed: Novcmbsr 27, 1985 gguitocuantarv M W
'Y,Yc 85 ogg '2 UNITED STATES OF AMERICA A70 :13 NUCLEAR REGULATORY COMMISSION (Frt: y c,,t y; 1:,
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before the SR ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445 Aj TEXAS UTILITIES GENERATING
)
50-446 UL COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
APPLICANTS' SECOND SUPPLEMENTAL RESPONSES TO
" CASE'S 8/27/85 INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE" AND REQUEST FOR PROTECTIVE ORDER Pursuant to its undertaking to re-respond to Interrogatory / Request No A-3, made in open court on November 12, 1985, the Applicants submit this supplemental answer.
Interrogatory / Request No. A-3 A-3.
Please provide the names, titles, position, responsibilities and complete resume on each individual who is in the second and third tiers under the mana Tement tiers given on Mr. Counsil's charts.
Please note which, if any of these individuals is not a full-time TUGCO employee and
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which are.
For each person who is not a full-time TUCCO employee, please provide full information on his or her employer, contractor, etc. and if that company, contractor, etc. has been hired as a consultant for the Comanche Peak project.
Objection (Partial):
The Applicants object to this interrogatory, on the ground that it is irrelevant to Contention 5, the only admitted contention in these proceedings and on the ground that it is unduly burdensome.
As framed, the interrogatory / request would require detailed information to be collected and supplied for approximately 350 persons, many of whom have and have had no responsiblity for the construction, design or testing of CPSES (including QA/QC in any of these areas).
Without waiving this objection, the Applicants will prepare a list of the persons reporting to those persons shown on the charts in question, and perwens reporting to them, for organizations other than the Manager of Nuclear Operations, Engineering and Administrative Services (which does cost and schedule analysis but no plant design), Health Physics Department and Nuclear Fuel, and the Applicants will, upon request made thereafter, produce for inspection.
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and copying the resume of any person shown on that list who has a resume, provided however, (i) that the Applicants do not admit that the material being produced is relevant to Contention 5 and (ii) that it will take approximately three weeks to collect the information described herein.
The Applicants move for a protective order on this objection.
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o-Signatures As to-Objections:
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Thomas G.
Digttan, Jr.
R. K. Gad IIII' Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for the Applicants Dated: November 27, 1985.
CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on November 27, 1985, I made service of the within document by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Herbert Grossman Chairman Alternate Chairman Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Walter H. Jordan Mr. William L. Clements Administrative Jt.r'ge Docketing & Services Branch 881 W.
Outer Drite U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Chairman Chairman Atomic Safety and Licensing Atomic Saf,ety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission 7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20814
i Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S.
Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.
2000 P Street, N.W.,
Suite 611 Suite 840 Washington, D.C.
20036 Washington, D.C.
20036 Dr. Kenneth A. McCollom Mr. Lanny A.
Sinkin Administrative Judge 3022 Porter Street, N.W.,
- 304 Dean, Division of Engineering, Washington, D.C.
20008 Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74078 Ms. Billie Pirner Garde Mr. Robert D. Martin Citizens Clinic Director Regional Administrator, Government Accountability Project Region IV 1901 Que Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C.
20009 Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.
Johnson Geary S. Mizuno, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Nancy Williams Mr. James E.
Cummins Cygna Energy Services, Inc.
Resident Inspector 101 California Street Comanche Peak S.E.S.
Suite 1000 c/o U.S. Nuclear Regulatory San Francisco, California 94111 Commission P.O.
Box 38 Glen Rose, Texas 76043 7[N-4 W"WWW/
omasgDignsri, Jr.
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