ML20205M183
| ML20205M183 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/20/1987 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#287-2938 OL, NUDOCS 8704020295 | |
| Download: ML20205M183 (9) | |
Text
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90CKETED USNRC Filed:
March 20, 1987 jd R 30 MI 53 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g
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y 00CKETING A SEE.'!C!
before the B R M.C H, ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445_gp
)
50-446 TEXAS UTILITIES GENERATING
)
(Application for an COMPANY et al.
)
Operating License)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
APPLICANTS' SUPPLEMENTATION TO THEIR ANSWERS TO CASE'S INTERROGATORIES TO APPLICANTS (August 27, 1985)
Without waiving their objections heretofore interposed, the Applicants hereby supplement their responses to " CASE's Interrogatories to Applicants (August 27, 1985)" as follows:
Interrogatory No. A-2:
Please provide all available information on each and every person who has now been hired or who is yet to be hired to
" fill in the blanks on (Mr. Counsil's organizational) chart (s)".
(Tr. 15/23-26/2; etc.)
Please provide a complete resume for each individual so named, and give all information (e.g.,
name, title, responsibilities, etc.) on the position he or she is/will do with TUGCO.
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Response
Updated organization charts are available for review.
Resumes will be obtained and provided if specifically requested.
Interrogatory No. 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 management tiers given on Mr.
Counsil's charts.
Please note which, if any of these individuals is not a full-time TUGCO employee and which are.
For each person who is not a full-time TUGCO 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.
Response
R.
D. Walker-Executive Assistant to W.G. Counsil (TU)
J.
W. Muffett - Executive Assistant to L.D. Nace (TU)
W.
R.
Deatherage - Director, Engineering Administration (TU) i J.
E.
Krechting - Director of Engineering (SWEC)
O.
W.
Lowe (SWEC)
P.
B. Stevens (TU)
R. D. Calder (TU)
J.
L. Barker (TU) l R. T. Jenkins (TU)
C. Carter (SWEC) l T.
G.
Tyler - Director of Projects (TU)
R. E. Camp (GENCO)
D. M. Reynerson (TU)
L. Sluiter (SWEC)
D. Hafstienn (TU)
J.
J.
Kelley - Director of Construction (TU)
H.
C. Dodd (B&R)
W. L. Nelson (TU)
M. M. Gonzalez (TU) i B. Ward (B&R) 1 l
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T. D. Hawkins - (G&H)
R.
P.
Klause - PSAS Project Manager (SWEC)
A. W. Chan (SWEC)
R.
L. Grubb - Site Manager (IMPELL)
L.
C. Schmitt (IMPELL)
J. V. Everett (IMPELL)
T. P. Desmond (IMPELL)
J. M. Park (IMPELL)
R. E. Walz (IMPELL)
R. C.
Iotti - Project General Manager - Vice President (EBASCO)
E. N. Odar (EBASCO)
R. H. Ackley, Jr. - CAC-ESG Project Manager (SWEC)
J. R. Peterson (SWEC)
S.
L.
Stamm (SWEC)
R. H. Murphy (SWEC)
J.
F.
Streeter - Director, Qualty Assurance (TU)
D. M. McAfee (TU)
P. E. Halstead (TU)
C. H. Welch (TU)
C. T. Brandt (EBASCO)
G.
S.
Keeley - Manager, Nuclear Licensing (TU)
P D. R. Woodlan (TU)
J. S. Marshall (TU)
L.
E.
Powell - Manager, Administration (TU)
S. S. Palmer (TU)
D. L. Anderson (TU)
W. D.
Fenoglio (TU)
T. L. Smart (TU)
L. W. Garner (TU)
G. M. Hamilton (TU)
D.
Ferguson - Director, CPRT (Delian) i R. Werner - Manager, SAFETEAM (TU)
F. Green (SYNDECO, Inc.)
T. Gibbs (NIC)
)
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4 J. C.
Kuykendall - Vice President Administration (TU)
J.
L. Brackney (TU)
H. J. Cheatham (TU)
Interrogatory No. A-4:
Please provide current updates in changes in positions and/or titles for each of the persons on each of Mr.
Counsil's organizational charts.
In particular, give complete information on each and every new individual who has been hired and/or transferred from another position to those positions, each and every person (e.g. Beck--Tr.
18/18-20--who was " filling in as manager of nuclear full (sic) and safety analysis" and George--Tr. 18/15-17--who was
" filling (in) as manager of engineering") now in those (and every other) spot.
Response
Updated organization charts are available for review.
Resumes will be obtained and provided if specifically requested.
Interrogatory No. H-3:
Provide the documents requested by Cygna in its 8/1/85 letter 84086.078 to John Beck, TUGCO (referring to a 6/27/85 request).
Response
The need to supplement these interrogatories has been superseded by the " Agreement Between CASE and Applicants Regarding Discovery Matters Relating to Comanche Peak Nuclear Power Plant" dated August 19, 1986.
Item 8 of the
" Agreement" provides that "Three copies of all letters, including those responding to specific Cygna questions, from Applicants to Cygna will be sent to Mrs. Ellis, at no charge to CASE, at the time they are sent to Cygna by Applicants Documents are currently being provided in accordance with the " Agreement", therefore, no further supplementation will be provided in response to Interrogatory Nos. H3 and H6.
Interrogatory No. H-6:
Provide CASE with copies of all documents supplied to Cygna in response to Cygna's questions (such as the ones which were attached to Cygna's 8/6/85 letter 84042.39 to CASE) at the time Applicants send them to Cygna.
(This is necessary because of the delay in CASE's receiving documents such as these.
The 8/6/85 letter from Cygna attached a 3" thick stack of doc.trconts with dates which ranged from September 1984 to June 17, 1985.
This long delay in receiving documents is unacceptable to CASE.
We believe that the most reasonable way to see that they are provided in a timely fashion is for Applicants to provide them to CASE at the same time they provide them to Cygna.)
Include in your response whether or not Applicants will voluntarily agree to provide CASE with such documents at the same time Applicants provide them to Cygna.
Response
The need to supplement those interrogatories has been superseded by the " Agreement Between CASE and Applicants Regarding Discovery Matters Relating to Comanche Peak Nuclear Power Plant" dated August 19, 1986.
Item 8 of the
" Agreement" provides that "Three copies of all letters, including those responding to specific Cygna questions, from Applicants to Cygna will be sent to Mrs. Ellis, at no charge to CASE, at the time they are sent to Cygna by Anplicants
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A Documents are currently being provided in accordance with the " Agreement", therefore, no further supplementation will be provided in response to Interrogatory Nos..H3 and j
H6.
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s 5ignatures As to Answers:
I, Debra L. Anderson, 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 insotar 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.
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Sworn to before me this 20th day of March, 1987
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000KETED USNRC CERTIFICATE OF SERVICE W ltAR 30 M1:33 i
I, Kathryn A.
Selleck, one of the attorneys for the Applicants herein, hereby certify that on March 20, 1987, I h iN Qhf l
BRANCH the within document by mailing copies thereof, postage prepaid, to Peter B. Bloch, Esquire Mr. James E. Cummins i
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 Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 l
Chairman Chairman i
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel j
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555 i
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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 Washi ngton, D.C.
20555 Anthony Roisman, Esquire Mr. Lanny A.
Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W.,
Suite 611 Washington, D.C.
20002 Washington, D.C.
20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.
Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director i
P.O. Box X, Building 3500 U.S.
Nuclear Regulatory Commission
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Oak Ridge, Tennessee 37830 Washington, D.C.
20555
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Nancy Williams Cygna Energy Services, Inc.
j 101 California Street Suite 1000 San Francisco, California 94111 W
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Kathryn A.
Selleck 1
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