ML20155G711
| ML20155G711 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/30/1986 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#286-048, CON-#286-48 OL, NUDOCS 8605070092 | |
| Download: ML20155G711 (5) | |
Text
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hTED 00mmM Dated:. April 30, 1986
?!)- u UNITED STATES OF AMERICA 00cHrrgp l
NUCLEAR REGULATORY COMMISSION USNRC before the-7 g-5 40:57 ATOMIC SAFETY AND LICENSING BOARD Li,,
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BRANCH
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i In the Matter of
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Docket Nos. 50-445 TEXAS UTILITIES GENERATING
)
50-446 COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric )
Operating License)
Station, Units 1 and 2)
)
.)
)
I APPLICANTS' FURTHER SUPPLEMENTAL RESPONSE TO
" CASE'S 8/27/85 INTERROGATORIES TO 4
APPLICANTS AND REQUESTS TO PRODUCE" (Interrogatory No. B-2)
The Applicants hereby further supplement their answer to Interrogatory No. B-2 of the set propounded by CAS'E on August 27, 1985, as follows:
Interrogatory / Request No. B-2 Please provide complete documentation of all instances of confirmation of allegations of harassment and intimida-tion by TUGCO.
-(Tr. 150/7-11.)
Further Response:
Insofar as this interrogatory references statements made by Mr. Counsil during the public mee. ting of June 13, 1985 (Tr. 150/7-11):
The allegation Mr. Counsil referred to came to his attention through the SAFETEAM program.
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Mr. Counsil deps not recall whether any specific fcctual details of that incident were provided to him at that timo, and he has no present recollection of any of the details of the incident to which the reference was intended.
The Applicants have made available material developed by SAFETEAM regarding concerns posed by or about QC inspectors and involving incidents or circumstances occurring prior to July 1,
1984, in response to Item 6(d) of the Request for Production of Documents served by CASE under date of September 4,
1985.
Consequently, documentation 1
regarding the allegation referred to by Mr. Counsil during the public meeting, if it falls within the present scope of discovery on such allegations as described
- above, has already been provided to CASE for inspection and copying.
Documentation generated prior to
- SAFETEAM, such as QA investigations, exit interviews, investigation
- reports, Ombudsman files, Hotline concerns and survey documentation has previously been made available to CASE in original and supplemental production in response to Item 3 of CASE's Eighteenth Set of Interrogatories.
t
v Signatures As to Answers:
I, William G.
- Counsil, being first duly sworn, do depose and say that I am Executive Vice President of Texas Utilities Generating
- Company, that I
am familiar with statements made in the foregoing
- answer, that I
have assisted in the preparation of the foregoing answer, and that the foregoing answer is true, except insofar as it is based on information that is available to TUGC0 personnel but not within my personal knowledge, as to which I,
based on such information, believe them to be true.
/f.
lWi/
William G.
Counsil Sworn to before me this
- nday of April, 1986:
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V Notary Public L My Commission Expires:
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CERTIFICATE OF SERVICE I,
Thomas G. Dignan, Jr. one of the attorneys for the Applicants herein, hereby certify that on April 30, 1986, I made service of the within Applicants' Further Supplemental Response to
" CASE's 8/27/85 Interrogatories to Applicants and Requests to Produce" (Interrogatory No. B-2) by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Mr. James E.
Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S.
Nuclear Regulatory Board Commission U.S.
Nuclear Regulatory P.O.
Box 38 Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H.
Jordan Mr. William L.
Clements Administrative Judge Docketing & Services Branch 881 W.
Outer Drive U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Chairman Chairman Atomic Safety and Licensing Atomic Safety 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 Ellic Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S.
Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555
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 Christic Institute 1107 West Knapp 1324 North Capitol Street Stillwater, Oklahoma 74075 Washington, D.C.
20002 Ms. Billie Pirner Cardo 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 Washington, D.C.
20555 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111
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