ML19345G874

Second Set of Interrogatories to Applicant & Requests to Produce Re Rock Overbreak & Fissure Repair.Citizens for Fair Util Regulation Response to Applicant Second Set of Interrogatories Encl.Related Correspondence

ML19345G874
Person / Time
Site:	Comanche Peak
Issue date:	04/13/1981
From:	Fouke R CITIZENS FOR FAIR UTILITY REGULATION
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML19345G875	List: ML19345G874 ML19345G876
References
NUDOCS 8104220596
Download: ML19345G874 (6)

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• EE.uTED CORRESPONDEN3 D ,,

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UNITED STATES OF AMERICA 8 APR 1 N 2'

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[ @ / /) BEFORE THEDocket ATOMIC SAF

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In'the Matter of ) Nps. 50-445 TEXAS UTILITIE'S GENERATING )

COMPANY, et al

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. ) (Application for (Comanche Peak Stea.1 Electric Operating License)

Station, Units 1 and 2) )

CFUR'S SECOND SET OF INTERROGATORIES TO APPLICANT AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. SS2.740b and 2.741, Citizens for Fair Utility Regulation ("CPUR"), hereby serves CFUR's Second Set of Interrogatories and Requests to Produce upon Texas Utilities Generating Company, et al (" Applicants"). Each interrogatory shall be answered fully in writit.g, under oath or affirmation, and include all pertinent information known to Applicant, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession,

! custody or control of Applicant, its officers, directors or members l

l as well as its employees, advisors or counsel. In answering

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each interrogatory and in responding to each request, please recite the interrogatory or request preceding each answer or 1

. response. 9503 g

These interrogatories and requests shall be continuing in 1i nature. Thus, any time Applicant obtains information which l

rend,ers any previous response incorrect or indicates that a y response was incorrect when made, Applicant should supplement 8 ] ()4 g g g g Q revious response to the appropriate interrogatory or

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request to produce. Applicant should also supplement its responses as necessary with respect to identification of l each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the

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substance of that testimony. The term."documentp" shall include

( any writings,' drawings, graphs, charts, photographs, and other l data compilations from which information can be obtained. We l request that at a date or dates to be agreed upon, Applicant make available for inspection and copying all documents subject

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to the requests set forth below.

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CFUR'S INTERROGATORIES AND REQUESTS TO PRODUCE i 1) Are there any instances of rock overbreak and fissure repair during the excavation for and the preparation for the i5 pouting'of the foundation of CPSES. Please answer separately '

i for Unit 1 and Unit 2.

l l 2) If your response to the preceeding interrogatory is anything l other than "No", answer the following separately for Unit 1 and Unit 2:

a. State the date of and describe in detail each such instance of rock overbreak and fissure repair;

b. Identify with particularity all reports, photographs, documents and other tangible items which document or otherwise identify each such instance of rock overbreak and fissure repair;

! c. Please attach copies of all items identified in your response to the preceeding sub-part of this interrogatory. -

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d. State the name, business, position, employer, and business address of each person who has knowledge of each j such instance of rock overbreak and fissure repair.

3) Identify each person, subcontractor or other business entity which was involved in any way with the excavation for the foundation of Unit 1 of CPSES. Please state the dates during which each such entity was involved in the excavation.

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4) Identify each person, subcontractor or othe'r business entity which was involved in any way with the excavation for the foundation of Unit 2 of CPSES. Please state the dates during which each such entity was involved in the excavation.

5) Identify each person employed by or affiliated with the Applicants which has knowledge of the excavation for the foundation of Unit 1 of CPSES. Please ' state the' dates of the excavation of which each such person has knowledge.

6) Identify each person employed by or affiliated with the Applicants which has knowledge of the e cavation for the foundation of Unit 2~of CPSES. Please state the dates of the

! excavation of which each such person has knowledge.

7) Identify with particularity all documents which reflect any excavation for the foundation of Unit 1 of CPSES.

8) Identify with particularity all documents which reflect any excavation for the foundation of Unit 2 of CPSES.

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9) Identify with particularity all documents which reflect the depth of excavation for the foundation of Unit 1 of CPSES.

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6 10) Identify with particularity all documents which reflect the depth of excavation for the foundation of Unit 2 of CPSES.

11) Please attach copies of all documents listed in your responses to the preceding four interrogatories.

12) Identify each person, subcontractor or other business entity which was involved in any way with the pouring of concrete' foundation of Unit 1 of CPSES. Please state the dates during which each such entity was involved in the pouring of concrete.

l 13) Identify each person, subcontractor or other business

! entity which was involved in any way with the pouring of concrete foundation of Unit 2 of'CPSES. Please state the ,

dates during which each such entity was involved in the pouring of concrete. ..

14) Identify each person employed by or affilia'ted with the .

l Applicants which has knowledge of the pouring of concrete for the foundation'of Unit 1 of CPSES. Please state the dates of the pouring of concrete of which each such person has knowledge.

15) Identify each person employed by or affiliated with the Applicants which has knowledge of the pouring of concrete for the foundation of Unit 2 of CPSES. Please state the dates of the pouring of concrete of which each such person has knowledge.

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16) Identify with particularity all documents which reflect any pouring of concrete for the foundation of Unit 1 of CPSES.

17) Identify with particularity all documents which reflect

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any pouring of concrete for the foundation of Unit 2 of CPSES.

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18) Identify with particularity all documents which reflect the depth of the concrete foundation of. Unit 1 of CPSES.

19) Identify with particularity all documents which reflect the depth of the concrete foundation of Unit 2 of CPSES.

20) Please attach copies of all documents identified in your responses to the preceding four interrogatories.

21) What is the depth of the concrete foundation of Unit 1

! of CPSES. Please' state the depth over the entire area of the' l concrete foundation.

22) What is the depth of the concrete foundation of Unit 2 of CPSES. Please state the depth over the entire area of the concrete foundation.

23) Identify all rock and other non-concrete material which was incorporated in the concrete foundation or otherwise 8 placed above the unexcavated bedrock before or during the pouring of concrete foundation for Unit 1 of CPSES.

24) For all material identified in your response to 'the pre-ceding interrogatory, answer the.following:

a. State'all dates upon which such material was placed over the bedrock or otherwise incorporated in the foundation j of Unit 1 of CPSES.

l l b. For each date identified, state the type of material l involved and the volume of material involved.

c. For each date identified, state the persons, subcontractors, and other business entities which were involved with the intro-duction of the material identified.

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d. Identify with particularity all documents which reflect the introduction of the material identified into the foundation of Unit 1 of CPSES.

i l e. Please attach copies of all documents ider.tified in

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your response to the preceding subpart of this interrogatory.

2. Why was the identified material incorporated into the foundation of Unit 1 of CPSES.

g. 2dentify the name, employee, buciness position, and address of all persons who have kr.owledge of incorporating the identified material into the foundetion of. Unit 1 of CPSES.

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25) Identify all rock and other non-concrete material which was incorporated in the concrete foundation or otherwise placed above the unexcavated bedrock before or during the pouring of concrete foundation for Unit 2 of CPSES.

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26) For all material identified in your response to the pre-ceding interrogatory, answer the following:

a. State all dates upon which such material w over the bedro.ck or otherwise incorporated in the, as placed

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l l b. For each date identified, state the type of material involved and the volume of material involved.

c. For each date identified, state the persons, sub-contractors, and other business entities which were involved with the introduction of the material identified.

d. Identify with particularity all documents which reflect the introduction of the material identified into the foundation of Unit 2 of CPSES.

e. Please attach copies of all documents identified in your response to the preceding subpart of this interrogatory.

1. f.'Why was the identified material incorporated into the foundation of Unit 2 of CPSES.

g. Identify the name, employee, business position, and address of all persons who have knowledge of incorporating the identified material into the foundation of Unit 2 of CPSES.

l 27) Identify the name, employer, business position and address of all persons who were present during the pouring of the foundation of Unit 1 of CPSES. Please state the dates during which each each persons were present.

28) Identify the name, employer, business position and address of all persons who were present during the pouring of the foundation of Unit 2 of CPSES. Please state the dates during which each such persons were present.

29) Identify with particularity all documents which reflect

• l the identity of persons which were present during the pouring l of the foundation of Unit 1 of CPSES.

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30) Identify with particularity all documents which reflect the identity of persons which were present during the pouring of the foundation of Unit 2 of CPSES.

31) Please attach copies of all documents identified in your responses to the two preceding interrogatories.

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Respectfully submitted,

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RICHARD L. FOUKE 1668B Carter Drive, -

Arlington, Texas 76010

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