ML20212E750
| ML20212E750 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/30/1986 |
| From: | Roisman A GREGORY, M., TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2083 CPA, NUDOCS 8701050435 | |
| Download: ML20212E750 (7) | |
Text
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O goggESPOI9 BEFORE THE D0LKETED usNRC UNITED STATES NUCLEAR REGULATORY COMMISSION L
'87 JM1 -2 P5 :33 Before the Atomic Safety and Licensing Board CFF; s
)
r,C m p.;;7 In the Matter of
)
TEXAS UTILITIES GENERATING COMPANY,
)
Dkt. Nos. 50-445-CPA et al.
)
)
(Comanche Peak Steam Electric
)
Station, Unit 1)
)
MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (Set 5)
Please respond to,the following interrogatories and requests for production of documents within the time limits specified by the NRC regulations and pursuant to the requirements of those regulations.
For purposes of this document, the following definitions and guidelines for clarifying answers are applicable:
" Applicants" refers to each owner of CPSES and to each a.
l contractor, subcontractor, and consultant.
Each answer should indicate that the answer represents the information in the possession of each and every owner and that inquiry has been made to each contractor, subcontractor, and consultant, including those no longer employed at the site, and the responses received from them, if any.
In addition, when information is obtained from an owner other than TUEC or from any contractor, subcontractor, or consultant, the specific information so obtained, particularly documents, chould 0701050433 861230 gDR ADOCK 05000 5
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T be identified by source whenever reasonably possible (i.e., from whom did TUEC obtain the information in order to answer the question or request?).
b.
" Documents" refers to everything ~ written or recorded in any way, including draf ts and otherwise identical copies of the same documents that contain substantive additions or deletions.
All interrogatories and requests should be regarded as c.
separable and objections to portions of interrogatories or requests do not relieve Applicants of the duty to answer the remainder of the interrogatories or requests.
f d.
Where objections are interposed but answers given, 1
please indicate to what extent the answer is a complete response and to what extent additional information is being withheld because of the objection.
e.
Identify all documents examined, used, and/or relied upon in answering each interrogatory.
The foregoiny definitions and guidelines are incorporated by reference into and are a part of each of the following interrogatories and requects.
Interrogatories (Answers due in 15 days.)
1.
When did Applicants first receive notice of the issues identified by the NRC's TRT reports and SSERs, and in what form did that notice come (i.e.,
NCR, IR, audit report, memorandum, consultant's report, e tc.) ?
2.
For each item identified in Interrogatory 1, identify what response was taken to the problem and by whom.
3.
If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken.
If that is because Applicants relied on a "second opinion,"
reason identify the individuals or organizations who provided that opinion.
4.
Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by others.
(For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC) ?)
5.
With referene"e to the ' attachment to the letter from Robert A. Wooldridge to' Foster DeReitzes dated December 23, 1985, which attachment was the " work specification on the retrospective audit," please answer the following questions:
What is the current status of that audit, and why is it a.
being conducted?
b.
To what extent have the work specifications been changed; what are the changes; who changed them; and why?
c.
When will the audit be completed?
d.
Why was the completion of the audit originally tied to a date shortly before anticipated fuel load of Unit 17 e.
Is it still tied to a date shortly before fuel load of Uni t 1, and, if so, why?
f.
What types of documents have been generated in the course of conducting the audit?
Please include within your answer handwritten notes, internal memos within the
, I
r organization (s) conducting the audit, progress reports to Appticants on the audit, minutes of meetings and notes by participants in meetings among the auditor personnel or between the auditors and any other persons.
9 Has the audit or any of the audit personnel reached any tentative or final conclusions on any subjects?
If so, what are those conclusions?
h.
Who is conducting the audit, and who at TUEC is supervising the conduct of the audit?
Request for Production of Documents (Answers due in 36~~ days.)
1.
With referencp to page 2 of Mr. Beck's letter to the mnority owners dated July 31, 1985, please provide a copy of the "Dreakdown of the 1978 MAC report findings to identify which items have been resolved by the project and which are being further addressed by the CPRT ef fort."
2.
With reference to Interrogatory 5, please provide a copy of all the documents the types of which are described in i
Interrogatory 5.f.
3.
With reference to Interrogatory 5, please provide a copy of all documents that define the nature of the audit and the relationship between TUEC and the auditors, including all contracting documents.
Portions of the documents that disclose the actual price of the work to be performed need not be disclosed.
4.
Produce the original or copies of all documents in Applicants' custody, possession, or control that were examined, used, and/or relied upon for answering Interrogatories 1 through L
4 S above.
If a document has already been supplied in this docket or in the OL docket, Applicants may identify with particularity the location of the document or answer by including the name of the document, page and line number, in which docket the document was produced, and the date it was produced.
This does not apply if the answer previously provided was an objection.
In that case, Applicants must reassert the obbjection to the extent applicable to this proceeding.
Respectfully submitted, m
~
/
M hg f
ANTHONY Z.
KIdpN Trial Lawy fs for Public Justice 2000 P S eet, NW, #611 Washington, D.C.
20036 (202) 463-8600 Counsel for Meddie Gregory Dated:
December 30, 1986 l 1
UNITED STATES 00'JESI NUCLEAR REGULATORY COMMISSION
~
Before the Atomic Safety and Licensinty Bgar42 P5 :33 In.the Matter of
)
CFFIE ' ',
^El
)
00Chilib l 4 2 hnta.
TEXAS UTILITIES GENERATING COMPANY,
)
Dkt. Nos'RANCF E 50-445-CPA et al.
)
)
(Comanche Peak Steam Electric
)
Station, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of MEDDIE GREGORY'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS (Set 5) were served today, December 30, 1986, by first class mai'1, or by hand where indicated by an asterisk, and by Federal Express where indicated by two asterisks, upon the following:
Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Walter H. Jordan Carib Terrace 552 North Ocean Blvd.
Pompano Beach, FL 33062 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, OK 74075 Elizabeth B.. Johnson Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, TN 37830 Nicholas Reynolds, Esq.
i Bishop, Liberman, Cook, i
Purcell & Reynolds l
1200 17th Street, NW Washington, D.C.
20036 l
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Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Geary S. Mizuno, Esq.
Office of Executive Legal Director U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road, 10th floor Washington, D.C.
20555 Thomas G. Dignan, Jr.
Ropes & Gray 225 Franklin Street Boston, MA 02110 lb b
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