ML20214L520
| ML20214L520 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/08/1986 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| CON-#386-614 OL, NUDOCS 8609100217 | |
| Download: ML20214L520 (7) | |
Text
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SDCOfmESPOW W BEFORd THE h
UNITED STATES DOCKETED NUCLEAR REGULATORY COMMISSION U WRC Betore the Atomic Satety and Licensing Board 16 SU' -8 R2 34 In the Matter ot
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0FFICL05 SicA;iARY
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00CKETihG A { LitytQ TEXAS UTILITIES GENERATING COMPANY,
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Dkt. Nos. 50-44$"# $"
0 et al.
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50-446-OL l
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l (Comanche Peak Steam Electric
)
l Station, Units 1 and 2)
)
l CASE INTERROGATORIES (9/5/86) j Pursuant to the regulations of tne Nuclear Regulatory Commission, CASE requests that Applicants Texas Utilities Electric Company, et al. ("TUEC") respond to the following interrogatories.
Instructions 1.
Each interrogatory should include all pertinent information known to Applicants and each of them (including minority owners), their of ficers, directors, or employees, their agents, advisors, or counsel.
" Employees" is to De construed in the Droad sense of the word, including specifically Brown & Root, Gibbs & Hill, Eoasco, Cygna, Stone and Webster, Evaluation Research Corporation, TERA, any consultants, subcontractors, and anyone else periorming work or services on behalf of the Applicants or tneir agents or subcontractors.
2.
Each answer should indicate whether it is based on the personal Knowledge at the person attesting to the answer, and, it not, on whose personal Knowledge it is based.
0609100217 060908 PDR ADOCK 05000445 0
3.
The term " documents" shall be construea in the oroad sense of tne word and snail include any writings, drawings, grapna, cnarts, photograpns, reports, studies, audits, slides, internal memoranda, informal notes, nanowritten notes, tape recordings, procedures, specifications, calculations, analyses, and any otner data compilations from which information can be obtained.
4.
Answer each interrogatory in tne order in which it is asked, numoored to correspond to the number of the interrogatory.
Do not comoine answers.
5.
Tnese interrogatories shall be continuing in nature, pursuant to 10 CPR 32.740(e) and the past directives of tne Licensing Board.
Supplementation shall be maae at least every two months to avoid resubmittal of tnese interrogatories.
Interrogatories These interrogatories concern the statement on page 7 of Applicants' Current Management Views and Case Management Plan (o/26/d5) that:
TUGC0 management is not satisfied with the status of tne plant and would not proceed to operate it, even if authority were to oc granted, until all of the outstanding concerns nave been aadressed, tneir satety signiticance determined, generic implications and collective significance considered, and necessary corrective actions have oeen completeo.
1.
Was tne quoted statement intenued to represent the opinion of TUGCO management?
2.
to wnoin a6es tne pnraue "fuuCO management" refer in tne quoted statoment?
wnat specific persons are inciuded in the
_2 h
phrase?
List them by name and position.
3.
Did all of TUGC0 management agree with the statement?
Identify specifically any members wno disagreed, listing them by name and position.
4.
For each inoividual identified in Interrogatory 23 a.
Identify the basis for nis or ner dissatisfaction with the status of the plant.
Describe specifically the concerns that gave rise to this dissatisf action and the f acts or opinions that gave rise to those concerns.
b.
Identify specifically the sources upon wnich the individual relied in forming his or her opinion, including any pertinent briefings or documents.
If it is possible to identify some but not all of these sources, so state.
Identity as many as possible and explain why the otners cannot be identified.
Upon which of these sources did the individual principally rely?
c.
Briefly describe each document identified in response to tnis Interrogatory.
Explain whether it was a memorandum produced specifically for the inoividual concerned, or some other kind of document, and, if so, what kind it was.
S.
For each individual identified in Interrogatory 23 a.
Explain specifically why he or sne would not have proceeded to operate tne plant at tne time the statement was made, even if authority had been granted to do so.
For instance, uid tnat inolvidual believe that it would not be possible to provide reasonable assurance that the health and safety of the public would not be ondangered by the operation of the plant?
I mjm
b.
Identity the sources for each individual's opinion described in S. 4., including any pertinent brietings or documents.
It it is possible to identify some out not all of these sources, so state; identify as many as possible; and explain why the others cannot ce identified.
upon which of tnese sources did the individual principally rely?
c.
Brietly describe each document identified in response to this Interrogatory.
Explain whether it was a memorandum produced specifically for the individual concerned or some other kind ot document, and, if so, what kind it was.
6.
For each inoividual identified in response to Interrogatory Ja a.
With which part ot tne statement did he or she disagreet b.
What were tne reasons for this oisagreement?
c.
What were the documents and other sources of inforsaation on which the individual relied in forming his or her opinion?
Include any pertinent brietings or documents.
On which sources aid the individual principally rely?
d.
Briefly describe each document identified in response to this Interrogatory.
Explain whether it was a memoranoum produced specifically for tne individual concerned or como other kind ot oocument, ano, it so, what kind it was.
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Respectfully submitted, 9%_
XNTHONY Z.
R M
Trial Lawy r for Public Justice 2000 P Street, NW, 4611 Washington, D.C.
20036 (202) 463-8600 Counsel for CASE t
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4 1
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4D Gonnt.bruisLUM UNITED STATES OF AMERICA DOLKETED NUCLEAR REGULATORY COMMISSION
'J 5Nk C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD WP -8 R2 34 In the Matter of
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0FFICE 0r H da iAh v J
00CKETING & SEPVICI.
TEXAS UTILITIES GENERATING
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BRANCH COMPANY, et al.
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Docket Nos. 50-445-OL
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and 50-446-OL (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
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CERTIFICATE OF SERVICE sy my signature below, I hereoy certify tnat true and correct copies of CASE's INTERROGATORIES (9/5/86) nave been sent to the persons listed below this 5th day of September 1986 by:
Express mail where indicated by *; Hand-delivery where indicated by * * ; and First Class Mail unless otherwise indicated.
Administrative Judge Peter B. Blocn U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Kenneth A. McCollom i
1107 West Knapp i
Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Elizabeth d. Johnson Oak Ridge National Laboratory P.O.
Box x, uuilding 3500 Oak Ridge, TN 378Jo Ellen Ginsberg, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1
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Robert A. Wooldridge, Esquire worsham, Forsythe, Sampels
& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201 Nicnolas Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 17 tn Street, N.W.
Washington, D.C.
2003o Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission hasnington, D.C.
20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Wasnington, D.C.
20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Cupreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 142u S. Polk Dallas, Texas 75224 Mr. W.G. Couns11 Executive Vice President Texas Utilities Generating Co.
Skyway Tower, 25th Floor t
l 400 N. Olive Street l
Dallas, Texas 75201 l
Mr. Roy P.
Lessy, Jr.
l Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Mr. Thomas G. Dignan, Jr.
Ropes & Gray' t
225 Franklin Street l
Boston, Massachusetts 02110 1
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