ML20155F703

Applicant Supplemental Responses to Case Discovery Requests.* Suppls Responses to Interrogatories 31 & 32 & Interrogatory 32 .W/Certificate of Svc. Related Correspondence

ML20155F703
Person / Time
Site:	Comanche Peak
Issue date:	06/10/1988
From:	Edgar G NEWMAN & HOLTZINGER, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
CON-#288-6518 OL, NUDOCS 8806170020
Download: ML20155F703 (10)

Text

. _ _ . _ .

(o$lY' m s

N S\ s EftAg.oCORRES M .D M Dated: June 10, 1988 1

c. -ym.

• UNITED STATES OF AMERICA

@D ($3Ig #g ,vaC% - k;S k/,/ m:ma \.

NUCLEAR REGULATORY COMMISSION i

,,Ufl 10 Etct 7 [

(

p@' cssC .-L J

--./A before the !d-ca % tw a a ru; a :a Nd[2 ATOMIC SAFETY AND LICENSING BOARD ./

4 ,s Q:? /

' t cJ,773~[ . 7 q )

In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES ELECTRIC )

COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

' Station, Units 1 and 2) )

) .

APPLICANTS' SUPPLEMENTAL RESPONSES TO CASE'S DISCOVERY REQUESTS 8

1 Applicants herewith provide supplemental responses f l

to Interrogatories 31 and 32 of CASE's 6/19/87 Interrogatories and Interrogatory 32 of CASE's 6/30/87 Interrogatories. +

I

< In providing these responses, Applicants do not waive their  ;

previous objections that these interrogatories request information which is irrelevant to the subject matter of this proceeding r

i and are not reasonably calculated to lead to the discovery i

of admissible evidence.

I 6/19/87 Interrogatories i Interrogatory No. 31:

a. How many individuals who are currently or were formerly i employed by Stone & Webster during the period June, 1986 through the present were former employees of NPS l Industries, ITT, Grinnell, Texas Utilities Electric

! Company, or one of its affiliated companies, Gibbs and r Hill, or any other of the Applicants or their agents,  ;

and worked at any time previously on the Comanche Peak l project (either onsite or offsite)?

l ,

8806170020 seo610 l

[

, _ _ . ~ .- . __ . . =.

f l s' l b. Provide a list of all such individuals, along with details

! of the dates they originally worked for the companies l in question, the dates they were hired by Stone & Webster for their assignment to work on Comanche Peak, their current job title and their last known address and telephone number.

Response

Applicants have obtained from Stone & Webster a listing of individuals who were employed by Stone & Webster during the period of June, 1986 to July, 1987, and who were former employees of NPSI, ITT Grinnel, TU Electric, Gibbs

& Hill, Tex-La Electric Cooperative of Texas, Inc., Brazos Electric Power Cooperative, Inc. or Texas Municipal Power l Agency, and worked on the CPSES project. The information requested by this interrogatory, such ac the date each individual worked for the aforementioned companies, the date the individual was assigned to CPSES, and their job title as of the date the inf-armation was gathered is also included on the listing.

This listing is available for inspection and copying in the Reading Room at the Dallas offices of TU Electric.

Interrogatory No. 32,:

a. How many individuals who are currently or were employed by Applicants or any of their consultants, contractors, subcontractors, or any other companies working on reinspection / reanalysis effort and/or the corrective actions resulting from such effort, during the period August, 1985 through the present, were former employees of NPS Industries, 1TT, Grinnell, Texas Utilities Electric Company or one of its affiliated companies, Gibbs and Hill, or any other of the Applicants or their agents, and worked at any time previously on the Comanche Peak project (either onsite or offsite)?

t l

3-

b. Provide a list of all such individuals, along with details of the dates they originally worked for the companies in question, the dates they were hired for their assignment to work on Comanche Peak, by whom they were hired, their current job title and status, and, if they were no longer employed at Comanche Peak, their last known address and telephone number.

Response: ,

Applicants' have obtained from Ebasco and Impell lists of individuals who were employed by Ebasco and Impell, respectively, during the period of August, 1985 to August, 1987, and who co ked on the reinspection / reanalysis aLd/or corrective action resulting from reinspection / reanalysis efforts associated with CPSES and who were former employees of NPSI, ITT, Grinnell, TU Electric, Gibbs & Hill, Tex-La Electric Cooperative of Texas, Inc., Brazos Electric Power Cooperative, Inc. or Texas Municipal Power Agency. In addition, Applicants have received from Ebasco a listing of additional Ebasco personnel who may have been previously employed by one of the aforementioned companies.

Applicants' have prepared a listing of individuals who were TU Electric employees from August, 1985 to August, l 1987 who previously performed work associated with CPSES for NPSI, ITT Grinnoll, TU Electric, Gibbs & Hill, Tex-La Electric Cooperative of Texas, Inc., Brazos Electric Power Cooperative, Inc. or Texas Municipal Power Agency.

l l

I

_4_

i The additional information requested by this interrogatory, such as the date each irdividual worked for the aforementioned ,

companies, the date the individual was hired by Ebasco, Impell, or TU Electric, and their job title as of the date the information was gathered.is.aleo included on the lists. These lists are available for inspection and copying in the Reading Room at the Dallas offices of TU Electric. l 6/30/86 Interrogatories Interrogatory No. 32:

a. How many individuals who are currently or were employed by Stone & Webster during the period August 1985 through June 1986 were former employees of NPS Industries, ITT Grinnell, Texas Utilities Electric Company or one of

. its affiliated companies, Gibbs & Hill, or any other 1 of Applicants or their agents, and worked at any time ,

previously on the Comanche Peak project (either onsite  !

or offsite)?

b. Provide a listing of all such individuals, along with  ;

• details regarding the dates they originally worked for the companies in question, the dates they were hired by Stone & Webster for their assignment to the reinspection / reanalysis effort c.t Comanche Peak, their current jcb title and status, and if they are no longer employed at Comanche Peak, their last known address and telephone number.

Response

l Pursuant to 10 C.F.R. 2.740(e)(2)(i), "Applicants' i

Supplemental Response to CASE's 6/30/86 Interrogatories and Request for Documents and Motion for Protective Order" cerved l

i  :

I

and filed June 8, 1987 is hereby further supplemented with the information contained on Attachment A.

Respectfully submitted.

TEXAS UTILITIES ELECTRIC COMPANY For the Owners of CPSES d4 "Ge'orge F. Edgar 47 /

Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, D.C. 20036 (202) 955-6600 Attorneys for Texas Utilities Electric Company 2

4 4

i i

2 4

A1TAf;H'lEN1 A ENi'Li>\ EE ASdlGNED TITLE STA'ild E'lPL Sole TO CPSES DATES

• • PREVIOUS EMPLOYER GIBBS & H1LL

t. ii Asu , D AV I D 05/85 'l1TLED ENGR. ClifRENT 1979-1981 DALS, VIRG1Lju 12/02/85 ENuk. OF F ki sLL il6 / 86- 10 / 8ti LO, ANDREW 05/x6 ENGR ,

O F F R o l.l. 1979-1981 Z1GMOND, EDWARD 01/86 TITLED ENGR. CURRENT 06/73-03/77

• • PRE \IOLS EMPLOYER ITT GRINNEl.L PRESCOTT, MICHAEL 01/86 ENGR CURRENT 11/76-08/85 s* PREVIOUS EMPLOYER TU SERVICES LAZAROVICH, JOHN 08/26/85 ENGR CURRENT 01/80-08/80 AND 06/81-U8/85 O

Sianatures i

As to Answers I, Susan S. Palmer, being first duly sworn, do depose and say that I am a Project Manager for the Generating Division of Texas Utilities Electric Company, that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are based on information that is available to the applicants but not within my personal knowledge, as to which I based on such information, believe them to be true.

Sworn to before me this 9th day of June, 1988

&) -

710L Notary Public /

My Commission Expires: II I ]IS lif'.

~

$ ^WOCORRESPONO

~

UNITED STATES OF AMERICA

{,A p DL .

NUCLEAR REGULATORY COMMISSION f. e~ '

before the

-d 170H1'6eT"_ .. .,

y' G. .

ATOMIC SAFETY AND LICENSING BOARD g gb cu SY '

)

In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES ELECTRIC ) [

COMPANY et-al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License) ,

Station, Units 1 and 2) )

)

CERTIFICATE OF SERVICE I, Thomas A. Schmutz, hereby certify that the fore-going Applicants' Supplemental Responses to CASE's Discovery Requests was served this 10th day of June 1988, by mailing copies thereof (unless otherwise indicated), first class mail, postage prepaid to

• Peter B. Bloch, Esquire *AdjudicLtory File (2 copies)

Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Docket Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Assistant Director for

• Alan S. Rosenthal, Esq. Inspection Programs Chairman Comanche Peak Project Division Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Panel Commission U.S. Nuclear Regulatory P.O. Box 1029 Commission Granbury, TX 76048 Washington, D.C. 20555

• / Asterisk indicates service by hand or overnight courier.

. f

• Juanita Ellis Robert D. Martin President, CASE Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory Commission William R. Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000

& Rothwell Arlington, Cexas 76011 Suite 700 1025 Thomas Jefferson St., N.W. Dr. Kenneth A. McCollom Washington, D.C. 20007 Administrative Judge 1107 West Knapp

• William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C. 20555 Suite 1250 1050 Connecticut Avenue, N.W.

• Billie Pirner Garde Washington, D.C. 20036 Government Accountability Project *Janice E. Moore, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C. 20555 Susan M. Theisen, Esquire Assistant Attorney General

• Anthony Roisman, Esquire Attorney General of Texas 1401 New York Avenue, N.W.

Environmental Protection Division Suite 600 P.O. Box 12548 Washington, D.C. 20005 Austin, Texas 78711-1548 Lanny A. Sinkin Robert A. Jablon, Esquire Christic Institute Spiegel & McDiarmid 1324 North Capitol Street 1350 New York Avenue, N.W. Washington, D.C. 20002 Washington, D.C. 20005-4798 Nancy Williams

• Elizabeth B. Johnson CYGNA Energy Services, Inc.

Oak Ridge National Laboratory 2121 N. California Blvd.

P.O. Box X Building 3500 Suite 390 Oak Ridge, Tennessee 37830 Walnut Creek, CA 94596

• Dr. Walter H. Jordan David R. Pigott 881 West Guter Drive Orrick, Herrington & Sutcliffe Oak Ridge, Tennessee 37830 600 Montgomery Street San Francisco, CA 94111

• Robert A. Wooldridge, Esquire

'Worsham, Forsythe, Sampels

& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201

• W. G. Counsil Executive Vice President Texas Utilities Electric -

Generating Division

-400 N. Olive, L.B. 81 Dallas, Texas 75201 l.

W Thomas A. Schmutz jr Dated: June 10, 1988 I