ML20236X245
| ML20236X245 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/02/1987 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20236X247 | List: |
| References | |
| CON-#487-4983 OL, NUDOCS 8712090069 | |
| Download: ML20236X245 (2) | |
Text
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December 2,1987 Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge -
Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson
- Administrative Judge Oak Ridge National Laboratory
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881 West Outer Drive P. O. Box X, Building 3500 l
Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station,
[
Units 1 & 2), Docket Nos. 50-445 and 50 446 C
Dear Administrative Judges:
In my letter to this Board of September 16,1985, a copy of which is attached, I advised the Board of three documents which appeared to be within the scope of and 1978 by Management Analysis Company ("MAC") ports prepared in CASE discovery requests. Those documents were re 1976, 1977, for Brown & Root concerning the Brown & Root Quality Assurance Program. In such letter,I stated that,"From our review, it appears that Applicants had no prior knowledge of the reports and did not have copies of the reports within their possession, custody, or control."
It has recently been brought to my attention that a Brown & Root May 14, 1976 response to TUSI Audit Report No. TBR-5 referred to QA audit consultant John P. Jackson. Mr. Jackson was at the time employed by MAC. Furthermore, Brown & Root's response to TUGCO Quality Assurance Audit Report TBR-6, dated L
January 26, 1977, makes reference to work performed by MAC for Brown & Root, l-Audit No. TBR.8, dated July 29,1978, refers back to this response. TU Electric l
audits of Brown & Root's Nos. TBR-1 through TBR-8, including follow-up documen-j tation, were first made aYailable to CASE in response to CASE Interrogatories Set i
1, Questions 8 and 11 by the Applicants' Response to CASE's Request for h
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Administrative Judges December 2,1987 Page Two Production of Documents dated August 11, 1980. These audits were also identified by CASE as CASE Exhibits 190A through 197E during the hearings conducted before this Board on July 28, 1982. They were accepted into evidence by this Board's Order dated December 7,1982.
Upon receiving the information that the Audit Report files made reference to work performed by.MAC for Brown & Root, I asked for and received confirmation from TU Liectric that, to the best of its present knowledge and available information, af ter several file searches, TU Electric did not in fact have copies of the Brown ~& Root audits performed by MAC prior to having received them from Brown & Root shortly before my September 16,1985 letter. I have also discussed this matter with D. N. Chapman, to whom the response to Audit Report No. TBR-6 was addressed. Mr. Chapman, upon reviewing the reports, vaguely recalled the.
audit responses in question but had not recalled Brown & Root's references to M AC in such responses at the time of the 1980 CASE discovery requests in this docket, or at any time thereafter. Mr. Chapman's supplemental affidavit is enclosed.
Based upon this additional information, my statement to you in my September 16,1985 letter is hereby corrected as apparer.tly TU Electric had been informed that MAC had furnished evaluations to Brown & Root in the late 70's although it did not have knowledge of the contents of the MAC reports to Brown & Root and were not provided copies until August of 1985.
We will continue to apprise the Board of any information obtained through the ongoing discovery and document review efforts at Comanche Peak which may bear on this matter or be required for discovery supplementation in this docket.
Respe y submitted, 2k jr v r w. -
Robert A. Wooldridge /
RAW /kiw Enclosures cc: ' Service List
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September 16,1985 CHA o M.
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Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Dean, Division of Engineering, Atomic Safety and Licensing Board Architecture and Technology U.S. Nuclear Regulatory Commission Oklahoma State University Washington, D.C.' 20555, Stillwater, Oklahoma' 74074
(
. Elizabeth B. Johnson '
Dr. Walter H. Jordan Oak Ridge National Latxratory 881 West Outer Drive P. O. Box X, Bu,1! ding 3500
- Oak Ridge, Tennessee 34830 Oak Ridge, Tennessee 34830 Re: Texas Utilities Electric Company, et al.
(Comanche Peak Steam Electric Station, Units I and 2); Docket Nos. 50-445 and 50-446
Dear Administrative Judges:
This will advise the Board and parties that Applicants have learned of three documents which appear to be within the scope of CASE discovery requests.
Applicants are providing these documents as a supplement to their responses to those requests. These documents are reports prepared in 1976,' 1977, and 1978 by the Management Analysis Company (MAC) for Brown & Root concerning the Brown
& Root quality assurance program.
Only portions of these reports concern Comanche Peak.
Discovery requests which Applicants believe apply to these reports are item 10 of CASE's first set of interrogatories, filed July 7,1980, and items 8 and 9 of CASE's tenth set of interrogatories, filed April 20,1982.
Applicants first learned of these reports following a recent interview of MAC by the NRC Office of Investigations on the subject of. additional work by MAC relating to Comanche Peak (other than the 1978 report commissioned by Texas Utilities and previously produced). Upon learning of the existence of the reports, Applicants promptly contacted Brown & Root and obtained copies of the attached
- documents last month. From our review, it appears that Applicants had no prior knowledge of the reports and did not have copies of the reports within their possession, custody, or control.
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1 Administrative Judges September 16,1985 Page Two l
Applicants a're fully ecgnizant of their obligation to provide full and complete answers to discovery requests and to supplement their responses when new 4
Information within the scope of those requests comes to their attention. As the Board is aware, at r. result of the discovery in Applicants' files of the M AC report 2
commissioned by Texas Utilities, Applicants have underway an extensive program to review past discovery requests and to search' company files for responsive
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materials which may not have been produced previously.
Sincerelh
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Robert A. Wooldridge For the Applicants 4
RAW /kiw Enclosures cc:
Service List
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