ML20209B058

Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence

ML20209B058
Person / Time
Site:	Comanche Peak
Issue date:	01/29/1987
From:	Selleck K ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
Shared Package
ML20209B035	List: ML20209B032 ML20209B058 ML20209B079
References
OL, NUDOCS 8702030511
Download: ML20209B058 (5)

Text

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4 RELAT ED CORiitSM.'i4UGUA 00L8 LIED '

U5tlRC Filed January 29, 1987 UNITED STATES OF AMERICA 87 FEB -2 All :02 NUCLEAR REGULATORY COMMISSION cF t , . -

00 '

before the \

ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-445,pg TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

APPLICANTS' INTERROGATORIES TO CASE (Set No. 1987-2)

Pursuant to 10 C.F.R. sec. 2.740 ff, the Applicants hereby propound the following interrogatories to " Citizens' Association for Sound Energy," (" CASE").

I-1. Does CASE contend that the CRT Program Plan, as written, is in any respect inadequate to achieve its stated objective? (If your answer to this Interrogatory is an unqualified negative, you may proceed to II-1).

I-2. Identify (by section, appendix, action plan and page number) each and every portion of the Program Plan that 8702030511 B70129 gDR ADOCK 05000445 PDR

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CASE contends is inadequate to achieve the stated Program Plan objective.

I-3. State, separately for each and every portion of the Program Plan required to be identified by Interrogatory I-2, each and every reason why CASE contends that portion is inadequate.

I-4. Does CASE intend to introduce the testimony of any expert on the issue of the adequacy of the CPRT Program Plan to achieve its stated objective? If so:

(1) Identify the expert; (ii) State the subject matter on which each expert is expected to testify; (iii) State the substance of the facts and opinions which each expert is expected to testify to; and (iv) Provide a summary of the grounds for each opinion to which each expert is expected to testify.

II-1. Does CASE contend that the CPRT Program Plan, as written, is in any respect inadequate to demonstrate the assurance required to satisfy the standard for determining whether issuance of an operating license should be authorized by the Licensing Board. (If your answer to this Interrogatory is an unqualified negative, you may proceed to III-1).

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'e II-2. State what CASE contends to be the standard for determining whether issuance of an operating license should be authorized by the Licensing Board.

II-3. Identify (by section, appendix, action plan and page number) each and every portion of the Program Plan that CASE contends is inadequate to satisfy the licensing standard.

II-4. State, separately for each and every portion of the Program Plan required to be identified in response to Interrogatory II-3, each and every reason why CASE contends that portion is inadequate to satisfy the licensing standard.

II-5. Does CASE intend to introduce the testimony of any expert on the issue of the adequacy of the CPRT Program Plan to satisfy the licensing standard? If son (1) Identify each expert; (ii) State the subject matter on which each expert is expected to testify; (iii) State the substance of the facts and opinions which each expert is expected to testify to; and (iv) Provide a summary of the grounds for each opinion to which each expert is expected to testify.

III-1. State all respects, if any, in addition to those described in your answers to the foregoing interrogatories, 3-

a b

in which, CASE contends that the CPRT Program Plan, "if implemented perfectly, will (not] be able to adequately resolve the questions" that exist regarding the adequacy of CPSES construction and design. See CASE Motion to Compel filed October 15, 1986 at 16.

III-2. State all respects, if any, in addition to those described in its answers to the foregoing interrogatories, in which, CASE contends that "CPRT (is] inherently incapable of" demonstrating that the facility should be granted an operating license. See Tr. 24588 (August 18, 1986).

III-3. State all matters, if any, in addition to those set forth in your responses to the foregoing interrogatories, that CASE intends to offer on "the question of the adequacy of the CPRT Program to respond to possible" QA/QC breakdowns. See Tr. 24587 (August 18, 1986).

III-4. Describe each of what CASE considers to be the

" generic CPRT issues" referred to in CASE's Proposed Schedule for Hearings, filed June 30, 1986 at 14-17.

III-5. Please state CASE's position on each of the

" generic CPRT issues" referred to in the previous interrogatory.

III-6. Identify each witness, document or other item of evidence upon which CASE intends to rely in order to establish its position on "CPRT adequacy" and each of the

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" generic CPRT issues" as referred to in Interrogatories III-l to III-5.

III-7. For each witness required to be identified in Interrogatory III-6, state:

(1) The witness's present residential and business addresses and telephone numbers.

(ii) The substance of the matters to which the witness is expected to testify.

By their attorneys, Thomas G. Dignan, Jr.

R. K. Gad III William A. Eggeling Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: (617)423-6100