ML20206P873
| ML20206P873 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/27/1986 |
| From: | Ellis J, Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-771 OL, NUDOCS 8607020259 | |
| Download: ML20206P873 (7) | |
Text
q"7/
ggo CORRtSPONUM BEFORE THE UNITED STATES 0
gf TED NUCLEAR REGULATORY COMMISSION NRC Before the Atomic Safety and Licensing B r4Jat g In the Matter of
)
Obh rIllR TI TARy
)
B
,?E Ntcf' TEXAS UTILITIES GENERATING COMPANY,
)
Dkt. Nos. 5 45-OL
_et _al.
)
50-446-OL
' (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
CASE REQUEST FOR PRODUCTION OF DOCUMENTS (June 27, 1986)
Pursuant to the regulations of the Commission CASE hereby requests that Applicants Texas Utilities Electric Company, et al., provide the following documents.
" Documents" means any writteni printed, recorded, typed, or other graphic or photographic matter of any kind or nature, and all mechanical or electrical sound recordings or a transcript thereof, any other sound reproductions, however produced or reproduced, and all copies of documents, by whatever means made, now or formerly in l
the possession, custody, or control of any of the Applicants, their agents or employees, or known by any of them to exist, including but not limited to studies, reports, minutes of i
meetings, memoranda (including but not limited to memoranda of meetings and phone conversations), letters, rules, pamphlets, calendars, flyers, books, booklets, cards, and brochures.
l I
i 8607020259 860627 PDR ADOCK 05000445 G
1.
All documents in the possession of any of the own'ers of Comanche Peak Steam Electric Station that were generated in the course of the " monitoring program.
undertaken by Tex-La in connection with Comanche Peak," including but not limited to all assessments, independent assessments, evaluations, interim reports, notes of meetings, and raw data generated.
See
" Permits / Licenses:
The Minority Owners' Responsibilities - The Function of Legal Counsel," presented by William H. Burchette, General Counsel, Tex-La Electric Cooperative of Texas, Inc.,
before the NRECA Committee on Joint Ownership Meeting, May 20-21, 1986, p. 5, hereafter "Burchette Speech" (copy attached).
Please include all documents (1) between the persons conducting the assesments, monitoring, and evaluation and the persons requesting such assessment, monitoring, and evaluation; (2) between the persons requesting such assessment, monitoring, and evaluation and other persons within Tex-La; and (3) between any person employed by, representing, or providing contracting or consulting services to Texas Utilities 81ectric Company or any of its parents, subsidiaries, or predecessors in interest and any person at Tex-La with respect to such assessment, monitoring, or evaluation.
2.
To the extent any monitoring, independent assessment, or evaluations were conducted by other minority owners of Comanche Peak at any time, all the documents as identified in Request fl, above, generated by these independent assessments, monitoring, or evaluations.
3.
All documents and all other information which provided the basis for the statement by Applicants in their Current.
Management Views and Case Management Plan (6/28/85), at 7, that TUGCO management is not satisfied with the status of the plant and would not proceed to operate it, even if authority were to be granted, until all of the outstanding concerns have been addressed, their safety significance determined, generic implications and collective significance considered, and necessary corrective actions have been completed.
4.
With respect to each document identified on Attachment 1 to Texas Utilities Electric Company, et al., Response to Interrogatories and Requests for Documents dated June 16, 1986, (CPA Dkt. )
a copy of all documents that (1) evaluate the findings and/or recommendatins in those documents, (2) propose actions to be taken in response to the findings and/or recommendation, and (3) direct implementation of any actions in response to the findings and/or recommendations.
5.
All documents upon which TUEC relied to support the following statements contained in its January 29, 1986, letter and request for extension of construction permit:
Applicants submit that good cause exists for the construction permit extensiont.j Lp. 13 Applicants submit that the delay which necessitates the construction permit extension was not the result of dilatory action by Applicantsl.J Lp. 2J LTJhere was no intentional delay of construction without a valid purpose.
Lp. 2J 6.
All documents that assess the status of the plant and that were presented at all of the periodic meetings of the Owners Committee and all minutes or other notes recording what transpired at those meetings where assessments were presented.
See durchette Speech, supra, p.
5.
I
~3-
i 9-c -,
ANTHONY Z.
O SMAN
'-, _ m%
i Trial Law er for Public Justice 2000 P Street, NW, #611 Washington, D.C.
20036 (202) 463-8600 Counsel for CASE i
h caa /u J
ITA ELLIS
/
1426 S. Polk Dallas, TX 75224 (214) 946-9446 Representative for CASE Dated:
June 27, 1986 I !
l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
(
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
)
)
and 50-446-OL (Comanche Peak Steara Electric
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's REQUEST FOR PRODUCTION OF DOCUMENTS (June 27, 1986) have been sent to the persons listed below this 27th day of June 1986 by:
Express mail where indicated by *:
Hand-delivery where indicated by **; and First Class Mail unless otherwise indicated.
Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 378JO Elizabeth B.
Johnson Oak Ridge National Laboratory P.O.
Box X, building 3S00 Oak Ridge, TN 37u30
Ellen Ginsberg, Esq.
U.6. Nuclear Regulatory Commission Washington, D.C.
205S5 Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels
& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201 Nicholas Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, N.W.
Washington, D.C.
20036 Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission j
Washington, D.C.
20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 Renea dicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S.
Polk Dallas, Texas 75224 Mr. W.G.
Counsil Executive Vice President Texas Utilities Generating Co.
Skyway Tower, 25th Floor 400 N. Olive Street Dallas, Texas 75201 Mr. Roy P.
Lessy, Jr.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 i
1 l
Mr. Thomas G.
Dignan, Jr.
Ropes & Gray 22S Franklin Street Boston, Massachusetts 02110
/*/k
)
&NTHONY Z.
MAR (
~~
,