ML20237L718

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Supplemental Responses to Case Interrogatories Re Mac Rept & Issues Raised by Mac Rept
ML20237L718
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/19/1987
From: Wooldridge R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
To:
Citizens Association for Sound Energy
Shared Package
ML20237F760 List: ... further results
References
NUDOCS 8708200309
Download: ML20237L718 (3)
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Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

4 In the Matter of  : l

Docket Nos. 50.445 i

< TEXAS UTILITIES ELECTRIC  : 50-446 l COMPANY, ET AL. 50.445-2 50-446-2 (Comanche Peak Steam Electric  :

Station, Units 1 and 2)  :

I APPLICANTS' SUPPLEMENTAL RESPONSES TO CASE'S INTERROGATORIES l RE: THE MAC REPORT AND I

!$5UES RAISED BY THE MAC REPORT Pursuant to 10 C.F.R. Sections 2.740b and 2.741, Applicants hereby provide their supplemental responses to CASE's Interrogatories in connection with the MAC Report and Issues Raised by the MAC Report dated June 24, 1985.

l Applicants' supplemental responses are governed by the Memorandum and Order entitled " Memorandum (Motions Relating to the MAC Report)" dated July 22,1985, and by the Memorandum and Order entitled " Memorandum (Status of Pending i

Motions)" dated October 29,1985.

1. On page 2 of Appilcants' 5/29/85 cover letter, it is stated that the MAC i Report was discovered "in gathering data for e prudence audit being 1 performed for TUEC," and other relevant details are given.

Provide the following regarding such prudence audit:

(d) Provide the name (and organization and title) of each Individual with each of the organizations i involved "in being audited"f In such(c) preceding prudence audit. who is primarily or actively Answer: As indicated in the response to 1.(c)in Appilcants' submittal ,

dated August 12,1985, the audit is being done solely for Texas Utilities i Electric Company and only Texas Utilities Company subsidiaries are 1 I

By Agreement between Ms. Ellis and Mr. Horin, the time for filing additional ]

j supplemental responses is December 6,1985.

)

Language of Interrogatory modified per Board Memorandum of July 22,1985, described above.

8708200309 B70019 ,

PDR ADDCK 05000445 G PDR

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being audited. Company individuals who have a p-imary management role in the audit are identified in the response to Interrogatory 1.(f) j which follows.

(f) Who (name, organization, title) determined the purpose and scope of i such audit? If such individual (s) consulted with others, provide the j l name, organization, and title of each such person. Include in your {

answer a brief discussion of how it was decidM that such an audit was I to be performed, the scope of such audit, what role each individual  ;

played in making such decisions, etc. (i.e., how the whole process evolved).

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Answer: After amendments to PURA in the 1983 legislature and the 1984 TUEC rate case,it became apparent to TUEC regulatory services Vice Presidents Messrs. E. L. Watson and T. L. Baker that prudence would become an issue. Through senior management discussion, M. D.

Spence, President of TUGCO, and E. L. Watson determined that a  !

Project Audit Team should be formed within TUGCO to assist in

' preparation and conduct of a prudence audit. A senior management group was formed to oversee the prudence audit. This group presently consists of Messrs. M. D. Spence, T. L. Baker, W. G. Counsil, Executive V. P., R. L. Gary, Executive V. P., Joe B. George, V. P., and R. A.

Wooldridge, Legal Counsel for TUEC. Mr. H. C. Schmidt, Manager of  ;

Nuclear Services, was appointed director of a Project Audit Team. The '

Project Audit Team, with assistance from Richard Metzler and Asso.

clates, a consulting firm, developed the general scope of the prudence audit. A copy of the work specification will be made available for 3 l

inspection. 1 (m) Which other audits, reports, analyses, etc., were reviewed or will be

{

reviewed by prudence auditors in connection with the prudence audit?

Answer: Attached are two lists (List A and List B) of audits, reports, i and analyses known to have been made available for review by the  !

prudence auditors in connection with the prudence audit.

'(s) Provide copies of all documents (in the broad sense of the word, as defined on page 2, item 3, of this pleading) regarding your answer to items (a) through (r) preceding.

Include copies of all draf ts of the prudence audit, as well as the final prudence audit itself. -

Answer: There have been no drafts of the prudence audit report, nor is there a final prudence audit report at this time. The other documents referred to in previous answers, including those in List A, attached, will be made available to CASE for inspection and copying at a time mutually convenient to CASE and the undersigned counsel for the Applicants at the offices of Texas Utilities Generating Company, 400 N. Olive Street, Dallas, Texas.

"Ihe documents identified in List B, attached, and described in answer to Interrogatory 1.(m) above, are believed by the Applicants to be outside of the scope of the " legitimate purposes" as described in the 2

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Board's Memorandum and Order of July 22,1985 (at page 2). Consistent with such Order, it ls App!! cants' understanding that interrogatories are to be answered "to the extent that they relate to the circumstances leading to the discovery of the MAC Report, the extent to which Appilcants' employees knew about that report, the root causes for falling to divulge the report, and the possible existence of other reports that may not have been revealed in response to discovery requests."

The documents described in List B, in Appilcants' view, do not relate to  !

any of the matters which remain in issue in the licensing proceedings.

This material would be " relevant only to CASE's . . . appearance before the public utility commission"(see page 2, Board's Memorandum of July 22,1985, as described above). Such being the case, Applicants do not believe it is appropriate to make these documents available for inspection and copying. Should CASE desire further explanation of the items on List B or question Applicants' position on this matter, the undersigned counsel for the Applicants is agreeable to consider this  !

matter further with CASE at any reasonable time.

Respectfully submitted, Nicholas S. Reynolds William A. Horin BISHOP, LIBERM AN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Suite 700 Washington, D.C. 20036 l (202) 857 9800 Thomas G. Dignan,3r.

R. K. Gad, m t ROPES & GRAY 125 Franklin Street .!

Boston, Massachusetts 02110 '

(617) 423-6100 Roy P. Lessy, Jr.

MORGAN, LEWIS & BOCK!US 1800 M Street, N.W. )

Washington, D.C. 20036 I (202) 872-5000 i Robert A. Wooldridge WORSHAM, FORSYTHE, SAMPELS l

& WOOLDRIDGE I l 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201 (214) 979 3000 ,

1 By ..

I Robert A. Wooldridge f N Counsel for Applicants l

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