ML20202C275
| ML20202C275 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/02/1986 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| CON-#386-934 OL, NUDOCS 8607110193 | |
| Download: ML20202C275 (7) | |
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CkLATEDC9P M M 00CKETED USNRC BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION *g jj, -9 gj kQ Before the Atomic Safety and Licensing Board UFf a,t u IEC2LIARY 00CKETING A SE%'ICT:
In the Matter of
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TEXAS UTILITIES GENERATING COMPANY, 1
Dkt. Nos. 50-445-OL
_e t _al.
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50-446-OL (Comanche Peak Steam Electric
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Station, Onits 1 and 2)
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i INTERROGATORIES AND REQUEST FOR DOCUMENTS (July 2, 1986)
Pursuant to the Rules of Practice, Citizens Association for Sound Energy (CASE) requests responses to the questions below and production of the sought after documents.
s Instructions 1.
Each interrogatory or document 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 anc. Webster, Evaluation Research Corporation, TERA, any 1
consultants, subcontractors, and anyone else performing work or i
services on behalf of the Applicants or their agents or subcontractors.
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4 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 i
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 i
authenticity or, pursuant to 52.742(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 52.740(e) and the s
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,
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identify it also by the name of the document.
8.
The following interrogatories and document requests should be answered in light of the interpretations,
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l clarifications, and guidance expressed in the Board's Memorandum and' order of June 27, 1986 (Dkt. No. 50-445-CPA).
Interrogatories 1
I.
Identify all documents upon which Applicants intend to i
rely in the construction permit extension proceeding (Dkt. No.
50-445-CPA) to demonstrate that there was a " good cause" for the delay in completion of construction of Unit 1.
j 2.
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 I
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 in Appendix B to CASB's Request for Imposition of Fine, j
Suspension of Construction Activities, and Hearing on Application to Renew Construction Permit, 1/31/86.)
3.
When did Applicants first receive notice of the issues identified by the NRC'is TRT reports and SSERs, and in what form l
did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.).
l 4.
For each item identified in Interrog.
3, identify what i
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response was taken to the problem and by whom.
5.
If the answer to Interrog. 4 is that no action was taken, explain the reason that no action was taken.
If that 3
reason is because Applicants relied on a "second opinion,"
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i identify the individuals or organizations who provided that judgment.
6.
Identify how each " finding" identified in Interrog. 3 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)?)
7.
State your position on the following, including all evidence and reasoning upon which you rely with respect to each positions What delayed completion of construction of Unit 1 I,
a.
past August 1, 1985?
b.
Why did that delay occur?
Who was responsible or that delay?
c.
d.
Do you believe you had a valid business purpose for the delay and, if so, what was it?
Identify each person who participated in the.
e.
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 of all documents in TUEC'1s 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 procoeeding, TUEC can identify with particularity the
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location of the document or answer by including the name of the 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, n
% nth 0NY Z OI{ MAN Trial Lawyers for Public Justice 2000 P Street, NW, #611 Washington, D.C.
20036 (202) 463-8600 Counsel for CASE Dated:
July 2, 1986 i ?.
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o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD a
In the Matter of
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TEXAS UTILITIES GENERATING
)
COMPANY, et al.
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Docket Nos. 50-445-OL
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and 50-446-OL (Comanche Peak Steam Electric
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i Station, Units 1 and 2)
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CERTIFICATE OF SERVICE i
By my signature below, I hereby certify that true and correct copies of CASE's INTERROGATORIES AND REQUEST FOR DOCUMENTS (July 2, 1986) have been sent to the persons listed below this 2nd day of July 1986 by:
Express mail where indicated by *; Hand-delivery where indicated by **; and First Class Mail unless otherwise indicated.
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Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 4
Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 W. Outer Drive j
Oak Ridge, Tennessee 37830 Elizabeth B. Johnson Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, TN 37830 l
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{l Mr. Thomas G.
Dignan, Jr.
Ropes & Gray 225 Franklin Street j
Boston, Massachusetts 02110 Mr. Thomas G.
Dignan, Jr. WW c/o Ropes & Gray 1001 22nd Street, NW, 7th floor Washington, D.C.
20037 I:
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