ML20198A100

Interrogatories & Request for Documents to Demonstrate Good Cause for Delay in Completion of Const & Basis for Util 850628 Statement That Plant Not Licensable at That Time. Certificate of Svc Encl.Related Correspondence

ML20198A100
Person / Time
Site:	Comanche Peak
Issue date:	05/15/1986
From:	Garde B GREGORY, M., TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Shared Package
ML20198A098	List: ML20198A093 ML20198A100
References
CPA, NUDOCS 8605200330
Download: ML20198A100 (7)

Text

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In.the Matter of )

)

TEXAS UTILITIES GENERATING COMPANY, ) Dkt. Nos. 50-445-CPA et al.- )

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2 )

INTERROGATORIES AND REQUEST FOR DOCUMENTS Pursuant to the Rules of Practice, Meddie Gregory requests responses to the questions below and production of the sought after documents.

We-expect responses to these interrogatories and/or requests for document production not later than 30 days after receipt of this request.

Instructions .

1. Each interrogatory or documer.t request should include all pertinent information known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel.

" Employees" is to be construed in the broad sense of the word, including specifically Brown & Root, Gibbs & Hill, Ebasco, Cygna, Stone and Webster, Evaluation Research Corporation, TERA, any consultants, subcontractors, and anyone else performing work or services on behalf of the Applicants or their agentns or subcontractors.

8605200330 860515 PDR ADOCK 05000445 0 PDR.

2. Each answer should indicate whether it is based on the personal knowledge of the person attesting to the answer and, if not, on whose personal knowledge it is based.

3. The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, audits, slides, internal. memoranda, informal notes, handwritten notes, tape recordings, procedures, specifications, calculations, analyses, and any other data compilations from which information can be obtained.

4. As to each document provided, applicants shall consider that providing the document constitutes an admission of its authenticity or, pursuant to 92.742(b), the basis for refusing to so admit.

5. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory.

Do not combine answers.

6. These interrogatories and requests for documents shall be continuing in nature, pursuant to 10 CFR $2.740(e) and the past directives of the Licensing Board. Supplementation shall be made at least every two months to avoid resubmittal of these interrogatories.

7. For each item supplied in response to a request for documents, identify it by the specific question number to which it is a response. If the item is excerpted from a document, identify it also by the name of the document.

Interrogatories-_ _

1. Identify all documents upon which Applicants intend to rely to demonstrate that there was a " good cause" for the delay in completion of construction of Unit 1.

2. Identify all documents and all other information which provided the basis for the statement by Applicants in their Current Management Views and Case Management Proposal (June 28, 19,85), at 7, that the plant was not licensable at that time.

3. Identify all audits, reviews, diagnoses, evaluations, consultant reports, in-house audits, or other reports which Applicants received from the beginning of construction to the present assessing, analyzing, commenting on, discussing, or offering an opinion on the plant's construction, procedures, compliance with industry or agency standards, or management style or competence. (This should include all source documents listed l in Appendix B to CASE's Request for Imposition of Fine, Suspension of Construction Activities, and Hearing on Application to Renew Construction Permit, 1/31/86.)

4. When did Applicants first receive notice of the issues identified by the NRC's TRT reports and SSERs, and in what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.).

5. For each item identified in Interrog. 4, identify what response was taken to the problem and by whom.

6. If the answer to Interrog. 5 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion,"

- . . _ -~.

identify the individuals or organizations who provided that judgment.

7. Identify how each " finding" identified in Interrog. 4 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?)

8. State your position on the following, including all evidence and reasoning upon which you rely with respect to each positions

a. What delayed completion of construction of Unit 1 past August 1, 19857

b. Why did that delay occur?

c. Who was responsible for that delay?

d. Do you believe you had a valid business purpose for the delay and, if so, what was it?

e. Identify each person who participated in the decision-making process that led to the delay and describe in detail their role.

Request for Documents CASE requests that Applicant produce the original or copies j of all documents in TUEC's custody, possession, or control that refer or relate in any way to documents identified in or used for answering Interrogatories 1 through 7 above.

If a document has already been supplied by TUEC to CASE in another prococeding, TUEC can identify with particularity the location of the document or answer by including the name of the a - . - -

b a -- - .-- -

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1 document, page and line number, in which docket the document was produced, and the date it was produced. This does not apply if the answer previously provided was an objection. In that case, TUEC must reassert the objection as applicable to this proceeding.

Respectfully submitted, Wu . "

ANTHONY.4. ROISMAN BILLIE P. GARDE Trial Lawyers for Public Justice 2000 P Street, NW, #611 Washington, D.C. 20036 (202) 463-8600 Counsel for Meddie Gregory Dated: May 15, 1986 S-

. o UNITED STATES NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

TEXAS UTILITIES GENERATING COMPANY, ) Dkt. Nos. 50-445-CPA

_e t _a l . )

(Comanche Peak Steam Electric )

Station, Units 1 and 2 )

CERTIFICATE OF SERVICE I hereby certify that INTERVENORS' PROPOSED DISCOVERY PLAN and INTERROGATORIES AND REQUEST FOR DOCUMENTS were served today, May 15,.1986, by first class mail, or by hand where indicated by an asterisk, upon the following:

Administrative Judge Peter Bloch*

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, OK 74075 Nicholas Reynolds, Esq.*

Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, NW Washington, D.C. 20036 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Stuart Treby, Esq.

Geary S. Mizuno, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

. WW Ah ANTHO g W ROISMAN

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