ML20235W193

Supplemental Response to Intervenors Document Production Requests.* Applicants Will Make Listed Matls Available to Intervenors Representatives for Exam & Copying in Dallas,Tx Ofcs.W/Certificate of Svc.Related Correspondence

ML20235W193
Person / Time
Site:	Comanche Peak
Issue date:	10/07/1987
From:	May J ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#487-4597 OL, NUDOCS 8710160044
Download: ML20235W193 (6)

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File g f ober'7, 1987 y in u ekqs UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMFf)KE ING F ERVICllELIONiECMTM:(

before-the suc ATOMIC SAFETY AND LICENSING p-

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.In the Matter- of )

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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445-OL and COMPANY et.al. ) 50-446-OL

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(Comanche' Peak. Steam Electric )

Station, Units 1 and 2) ) '

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s SUPPLEMENTAL RESPONSE TO INTERVENERS'~ DOCUMENT PRODUCTION REQUESTS Pursuant to 10 C.F.R. 52.740(e)(2)(1), Applicants' responses to Interveners' Discovery Requests are hereby supplemented-and amended by the materials identified on Attachment "A" hereto. These materials have been discovered during the continuing document reviews! undertaken by TU Electric.

• While Applicants are not sure all of these materials are in fact responsive to any specific document production 1 Including, for example, the files review committed to in

" Applicants' Responses to CASE's Interrogatories Re: The MAC Report and Issues Raised by the MAC Report," at No.

3(a). August 12, 1985.

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request submitted by the Interveners, it has been decided to make them available in order to continue Applicants' efforts to fully comply with all legitimate document production ,

requests. The re. fore , without conceding the relevance, materiality or responsiveness of these materials to these proceedings or to any particular document production request j submitted therein, Applicants will make the listed materials available to Interveners' representatives, for examination j and copying in the Dallas offices of TU Electric upon appropriate request at a mutually convenient time.

l TEXAS UTILITIES ELECTRIC COMPANY For the Owners of CPSES ,

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Wi ll (amle. Eppeling Je fdrey H. M4y j Ropes & Gray j 225 Franklin Street l Boston, Massachusetts 02110 l (617) 423-6100 j Attorneys for Texas Utilities Electric Company l

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6 ATTACHMENT "A"

1. Varicus memoranda, logs and other documents related to Hayward-Tyler Pumps.

2. Various memoranda and other documents reltated to ASME evaluations..

3. Various memoranda, logs and other documents related to trending. ,

4. Various memoranda, procedures and other documents related to QA Program.

5. Various memoranda and other documents related to concrete placement.

6. Reproduction of slides used by Sargent & Lundy, Engineers, during an oral presentation given to TUSI personnel in connection with consulting services performed during March-April 1982.

7. The service agreement dated February 18, 1982, between Texas Utilities Services, Inc. and Sargent & Lundy, , l Engineers, commissioning Sargent & Lundy's consulting and ,

advisory services during March-April 1982.

8. Notes of TU Electric personnel relating to CPSES q Office of Project General Management staff meetings during '

certain periods of 1978-79.

9. Muenow and Associates " Report on the Concrete Evaluation in Dome Roof Section of Comanche Peak, Unit 1,  ;

Glen Rose, Texas," dated June 16, 1979. '

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10. Brown & Root Vendor Surveillance Audit No. VS-1, dated July 29, 1976.

11. ANSI N626.0 Audits by Hartford Steam Boiler  !

Inspection and Insurance Agency, 1984 to present.

12. Various purchase orders / contracts associated with l CPSES. j i

13. The following documents prepared by Management j Analysis Corporation: i a- TUSI TPM/PMCS Development Project, dated April 25,  !

1979. (Previously identified in response to MAC g Set of Interrogatories, List B)  ;

1 b- TPM Software Tradeoff Study, dated May 2, 1978. 1 (Previously identified in response to MAC Set of )

l Interrogatories, List B) '

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c- Diagnost'ic of Engineering and Construction L. Organization, dated November 19, 1979. (Proposal l

and purchase order were previously provided in response to. CASE's 9/4/85 Set of Interrogatories) d -- Results and' Recommendations of the Project'

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Management System' Mini-Diagnostic,' covering January 23-26, 1978. (Proposal and purchase order were previously provided!in response to CASE's 9/4/85

-Set of Interrogatories)-

e- ' Preliminary TUSI PMCS Specification prepared by MAC l and TUSI Technical Services (Previously identified-in response to MAC Set of' Interrogatories, List B).

.14. Various memoranda relating to disposition of NCRs.

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uYNYC CERTIFICATE OF SERVICE y g 14 P4 :18 I, Jeffrey H. May, hereby certify that g hNfl987, I made service of " Supplemental Response to Interveners' Document Production Requests" by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Asst. Director for Inspection Chairman Programs i Administrative Judge Comanche Peak Project Division Atomic Safety'and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P. O. Box 1029 l Commission .

Granbury, Texas 76048 .

. Washington,: D.C. 20555 -

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, Dr.' Walter H. Jordan Ms. Billie Pirner Garde ~

Administrative Judge GAP-Midwest Office .'

881'W. Outer Drive 104 E. Wisconsin Ave. -B Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 1

' Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing  ;

Appeal Panel Board Panel i U.S. Nuclear Regulatory U.S. Nuclear Regulatory  ;

Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Janice E. Moore Mrs. Juanita Ellis Office of the General Counsel President, CASE U.S. Nuclear Regulatory 1426 S. Polk Street Commission Dallas, Texas 75224 ,

Washington, D.C. 20555  !

Renea Hicks, Esquire Ellen Ginsburg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P. O. Box 12548 U.S. Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C. 20555 I

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Anthony Roisman, Esquire Mr. Lanny A. Sinkin Suite 600. .

Christic Institute 1401 New York Avenue, N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington,.D.C. 20002 3

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, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P. O. Box X, Building 3500 U.S. Nuclear Regulatory Oak Ridge, Tennessee -37830 Commission '

Washington, D.C. 20555 .

Nancy H. Williams 2121 N. California Blvd.

Suite 390 Walnut Creek, CA 94596 1 h Jeff}eyH. f4ay i

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