ML20212D051

Applicant Interrogatories to Intervenor (Set 1987-6).* Set of Interrogatories Re Identifying Experts Consulted W/Or Retained by Intervenor W/Respect to Problems in Facility. Related Correspondence.Certificate of Svc Encl

ML20212D051
Person / Time
Site:	Comanche Peak
Issue date:	02/26/1987
From:	Selleck K ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
CON-#187-2630 OL, NUDOCS 8703040051
Download: ML20212D051 (7)

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DOCKETED Filed: February 26, 1987C UNITED STATES OF AMERICA '87 ItAR -2 P3 :17 NUCLEAR REGULATORY COMMISSION g r, 0 G:.

before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES GENERATING )

COMPANY et al. )

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

Station, Units 1 and 2) )

)

)

APPLICANTS' INTERROGATORIES TO INTERVENOR (Set No. 1987-6)

Pursuant to 10 C.F.R. I 2.740 ff the Applicants propound the following interrogatories to the Intervenor CASE.

Definition As used in these Interrogatories, the following term has the following meaning:

" Identify" with respect to an expert means to stater (a) The name, mailing address, age and present professional or employment affiliation of the person; 8703040051 870226 gDR ADOCK 05000445 PDR 0

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s (b) The profession or occupation and field of claimed expertise of the person; (c) The history of formal education or training of the person, including, but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to,

, (i) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; (e) The history of membership of the person in any professional or trade association in the area in the claimed expertise, including, but not limited to, (i) the name of each professional or trade association, (ii) the dates of membership, and (iii) a description of each office held in each association; (f) A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (1) the title and subject matter,

s (ii) the name and address of the publisher, and (iii) the date of publication; (g) A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; (h) The amount of time the person has worked in the field of claimed expertise, stating periods where work was other than on a full-time basis; (i) The name and address of every person, or every corporation or other institution, that has employed the person within the last ten years of-employment; (j) All periods of claimed self-employment, including a description of all duties and responsibilities thereof; (k) All previous experience in the field of claimed expertise which involved problems, analyses or studies similar to those with which the person is currently working; (1) All litigation in which the person has been

, consulted, specifying those matters in which the 1- -

person has testified, including the name of the case or matter and the court or other forum in which testimony was given; and (m) Any other experience in the field of claimed expertise.

Wherever appearing in these Interrogatories, the masculine form is defined to include the feminine and/or the neuter and the singular form is defined to include the plural wherever necessary to apply the context to any factual situation that may exist or to render the Interrogatory more inclusive in scope.

Interrogatory No. 1 Please identify each and every expert whom the Intervenor has retained or with whom the Intervenor has consulted with respect to the identification and/or correction of any problems in the Comanche Peak Steam Electric Station or the review or assessment of the adequacy or performance of the Applicants or the CPRT in any respect, including, without limiting the generality of the foregoing, the person (s) with whom CASE consulted and/or who assisted h

h CASE in the formul' a tion of its CPRT Interrogatories - Set No. 12.1 TEXAS UTILITIES ELECTRIC COMPANY For the Owners of CPSES By its attorneys, Thomas G. Dignan, Jr.

R. K. Gad III William S. Eggeling Kathryn A. Selleck ROPES & GRAY 225 Franklin Street Boston, MA 02110 (617) 423-6100 1

Please note that this interrogatory is not limited in scope. If and to the extent that CASE believes that this interrogatory requests information that may not properly be sought on discovery, CASE should object to the interrogatory and set forth sufficient information regarding the nature of the' expert's retention and functions to permit a ruling to be made. CASE's attention is called to the provisions of 10 C.F.R. sec.

2.740(b)(3), to Fed. R. Civ. P. 26(b)(4)(B), as interpreted by, e.g., Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), LBP-83-17, 17 NRC 490 (1983), and to the rulings of the Board at Tr. 24793-24794 (12/15/86).

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. t' CERTIFICATE OF SERVICE i i I, Kathryn A. Selleck, one of the attorneys for the Applicants herein, hereby certify that on February 26, 1987, I made service.of the within document by mailing copies thereof, postage prepaid, toe, i

1 Peter B. Bloch, Esquire Mr. James E. Cummins l 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 L

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 Chairman Chairman Atomic Safety and Licensing i

Appeal Panel Atomic Safet and Licensing Board Panel 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 '

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s 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 Washington, D.C. 20555 Anthony Roicman, 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 Oak Ridge National Laboratory Office of the Executive Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111 L 1 UL Kathryn A. Selleck l

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