ML20207F774
| ML20207F774 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/16/1986 |
| From: | Powell L TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20207F742 | List: |
| References | |
| CPA, NUDOCS 8607220609 | |
| Download: ML20207F774 (7) | |
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JUL 16 '96 13:32 LICENSING-TUGCO PAGE.02 APPENDIX TO APPLICANTS' RESPONSE TO " CONSOLIDATED INTERVENORS' RESPONSE TO MOTION FOR CLARIFICATION AND OPPOSITION TO REQUEST FOR PROTECTIVE ORDER" AFFIDAVIT OF L. ED POWELL THE STATE OF TEXAS 8
COUNTY OF DALLAS BBFORB MD, the undersigned authority, a Notary Public in and for Dallas County, Texas, on this day personally appeared.L. ED POWELL, who by me bcing duly sworn upon his oath deposes and says:
I, L. Ed Powell, having been duly sworn, hereby maka 3
affidavit as follows:
4 1.
I'am the Executive Assistant to the Vice President responsible for Quality Assurance, Fuel Servicae and Nuclear Licensing for Texas Utilities Generating Company.
Among my duties has been the coordination and direction of available resources employed by TUEC on the Comanche Peak Projcet for the purpose of obtaining information and identifying documents responsive to the discovory requests directed at Applicants.
As such, I have personal knowledgc of the facts stated herein.
2.
When discovery in the separate Construction Permit Extension proceeding began, knowledgeable individuals were identified who could provide analysis or input regarding the proper responses to the numerous questions asked in the many I
different areas and disciplines into which those qucations reached.
Because of the extraordinarily far-ranging nature of the questions - both substantively and temporally - we were obliged to identify and coordinate with a large number of people in order to respond to discovery in this proceeding.
These individuals were contacted, provided i
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copies of.the questions, and given due dates by which their
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input was needed.
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i JUL 16 86 13:32 LICENSIdG-TUGCO PAGE.03 3.
We approached the task in the relative order of priority outlined for us by our lawyers, seeking first to answer Set One questions, then Set Four, Sct Three and Set Two in that order.
4.
Our responses to the Set one questions were filed on June 17, 1986 with advance copies hand delivered to the Intervanors, Staff and the Board.
This effort required the involvement of eight projcot and management
- people, excluding cicrical and legal personnel.
5.
By June 27, 1986, over 12 additional people were directly involved in providing answers to the Intervenors' additional sets of discovery requests (i.e. Sots Two, Three, and Four).
During this same time period, Intervenors spent two days in our offices (June 25 and 26) reviewing documents provided in response to set one, question 3 which required attention from my staff which was diverted from working on i
responses to questions in Sets Two, Three and Four.
At the same Lime, responses also were being prepared to certain questions from the five sets of interrogatories related to credibility which were submitted on June 30, 1986.
Key individuals whose input was needed on the Set Two and Four questions were engaged in responding to the credibility questions.
6.
The Board's Order of June 27 requiring further response to the set one questions was received late Friday afternoon, at which time we further intensified our efforts.
Discussions were held on Friday and over the weekend with Senior Management and others to identify resources that would be required in addition to those already committed to providing responses to the questions in sets Two, Three, and I
Four.
Because of the late Friday afternoon timing of the Board's Order, it was impossible to begin mobilizing a significant response effort until the following Monday, June 30, 1986.
Approximately 45 man-hours wcro spent on the weekend by six people in preparing to respond to the Board's June 27 Order..
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JUL 16 '86 13:33 LICENSING-TUGCO PAGE.04 7.
After June 27, 1986, we were engaged in responding further to Questions 1
and 3 of Set one by July 3 in accordance with the specific terms of the Board's June 27 f
Order.
More than 60 people were directly involved in that and required the task alone, which took over 480 man-hours,_
services of individuals who have an important role in the ongoing work ~on the Comanche Peak Project.
8.
During this same time, i.e. June 30 through July 3, f
additional personnel resources were directly involved in the efforts to respond to the Board's directive on Set One, questions 4-7.
During this time more than 290 man-hours were expended by 24 project people.
9.
We had also scheduled responses to the interrogatories in Set Four to be prepared for service on Monday, July 7.
By July 2, substantial work had been done f
on preliminary compilations of responsive information, but j
it had been projected that a minimum of 124 additional i
project man-hours (excluding clerical, management reviews and legal time) would be required through the long Independence Day holiday weekend.
We had already informed 1
'l the key people involved in responding to the Set Four questions, as well as those involved in responding to questions 4,
5, 6,
7 and 8 in Set one, that they and whatever other personnel they needed to support their efforts would not be able to take the long-planned holiday.
10.
Similar efforts consistent with our already established schedule were underway simultaneously with regard to the responses required for Sets Two and Three.
11.
Upon receipt of the Appeal Board's Order of July 2,
[
1986, I began in mid-afternoon of July 2,
to inform the approximately 40 people werking on the Construction Permit Interrogatories that we would not require them to work on the Fourth of July Holiday weekend.
My instructions to these people were to continue working through July 2 and July 3 (except for those people who had previously planned to take July 3 off) and that subsequent instructions would
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.a i JUL 16 '86 13:35 LICENSING-TUGCO PAGE.01 be given on July 7.
At the end of the day on July 2,
- 1986, my understanding was that deadlines for filing all further responses to the Construction Permit Interrogatorica were in abeyance.
12.
When I
received word of the Appeal Board's subsequent Order on reconsideration the morning of July 3, I issued instructions to complete and submit responses to questions 1 and 3 of Set one by the end of the day.
These responses were the only ones that had been planned for submittal on July 3 prior to the Appeal Doard's July 2, 1986 Order.
It took available resources virtually all day on July 3 to finalise the responses to qucations 1
and 3
(including management review and transmittal to the intervonor).
No other responses were ready for filing on July 3, nor could any others have been made ready for filing by that date.
13.
Our projections, based in substantial part on i
I actual work done, are that it would have required over 320 man-hours of offort to completc the taok of asacabling and preliminary drafting all the information required to answer the Consolidated Intervenors' interrogatories and to identify, preliminarily screen, and make available all the documents called for by their document production rcquento (exclusive of questions 4 through 7 in Set One).
14.
Based upon thosc facts, it io cicar to me that -- given the available resources -- it would havo been impossible to have those answers and responoen prepared in time for filing and service on July 3, even if that had been the deadline, i"
15.
Because much of the discovery requires the input from the same people and examination of the same records, it is not always possible for this effort to be performed simultaneously regardless of how many people were availabic to assign to the tasks.
For that reason, it was becoming l ;
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,.4 JUL 16 'es 13:35 LICENSING-TUGCO PAGE.02 l
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apparent on July $ 2 and 3 that following the Appeal Board's I
order of July 2, 1986, the discovery responses to all of the questions might not have been ready on July 18, 1986, under the best of circumotances had we continued with our maximum efforto after July 3, 1986.
This estimate of completion does not include responses to Set One questions 4-7.
Completion of these responses by July 18, 1986 is impossible; 'I currently estimate that the effort on these questions would take approximately seven man-years to complete, and require the efforts of 30 to 40 people.
16.
Through July 3, 1986, over six man-months of effort had been expended on the Construction Permit Interrogatories.
'b L.
ED POWELL l
SUBSCRIBED AND SWORN TO before me by the said L. ED POWELL on this, the lfd day of k d 1986.
V U
M Notary Public"in and for Dallas County, Texas
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My Comunission Expires:
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CERTIFICATE OF SERVICE I,
William S.
Eggeling, one of the attorneys for the Applicants herein, hereby certify that on July 16, 1986, I made service of the within " Applicants' Response to ' Consolidated Intervenors' Response to Motion for Clarification and Opposition to hequest for Protective Order'" by placing the same in the hands of Federal Express, charges prepaid (except that, where indicated by an asterisk, ordinary first class mail used), to:
i 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 East West Towers Building 4350 East West Highway Bethesda, MD 20814 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 Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S.
Nuclear Regulatory Dallas, Texas 75224 Commission 7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20814
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- Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division P.O.
Box 12548, Capitol Station Austin, Texas 78711 Anthony Roisman, Esquire Executive Director Trial Lawyers for Public Justice 2000 P Street, N.W.,
Suite 611 Washington, D.C.
20036 Dr. Kenneth A. McCollom Administrative Judge 1107 West Knapp Stillwater, Oklahoma 74075
- Mr. Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Geary S. Mizuno, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814
!i William S.
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