ML19330B211

First Set of Interrogatories Directed to Applicant.Requests Details of Signed Sale Negotiations.Certificate of Svc Encl. Related Correspondence

ML19330B211
Person / Time
Site:	Comanche Peak
Issue date:	07/07/1980
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8007310123
Download: ML19330B211 (6)

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UNITED STATES OF AMERICA 4 NUCLEAR REGUIATORY C0t44ISSION O N USNRC ,

BEFORE THE ATOMIC SAFETY AND LICENSIE 30ARD 3

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JUL 2 01980 m  :

In the Matter of l Office cf the Secretjfy D"i & Service

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I q Branch APPLICATION OF TEXAS UTILITIES l .

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GENERATING CCMPANY, ET AL. FOR AN l Docket Nos. 50-45 OPERATING LICENSE FOR COMANCHE l and 50-W6 PEAK STEAM ELECTRIC STATION l -

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CASE FIRST SET OF INTERROGATORIES

TO APPLICANT Pursuant to 10 CFR g 2 7h0(b), Intervencr DASE (Citizens Associatica for Sound Energy) requests that the attached Interrogatories be answered fully, l

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in writing, and under oath by the officers or employees of the Applicants who have personal knowledge thereof or are the closest to having personal kncvledge

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thereof. Provide the name, title, and company affiliation of each person answering Interrogatories, together with an identification of which Interrogatories such person is responsible for answering. l 1

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1 Each Interrogatory has been identified as to which specific accepted

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Contention it pertains to.

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1. Supply copies of each and every Deficiency and Disposition Reprt (DDR) log.

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2. Supply copies of each and every Non-Conformance Report (NCR) log.

3 Supply copies of each and every Field Reqnst for Engineering . -tion (FREA) log.

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4. Supply copies of each and every Corrective Action Request (CAR) log.

5 Supply copies of each and every Concrete Pour log.

6. For items 1 through 5, supply a signed statement' that each and every log requested has been supplied, and that there are and have been no

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others. .

7 For items 1 throu6h 5, supply full-size, rather than reduced, copies

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of each. ,

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8. How many internal audits have the Applicants performed on Brown and Root?

9 How many audits have been performed by insurers (industrial risk, builder's risk, etc.) on vork done at the Comanche Peak plant?

10. How many outside or sub-contractor evaluations, studies or audits have been conducted (by sub-contractors o'r agents of sub-contractora or by consulting firms or others, etc.)?

11. Regarding items 8 through 10, provide the following information:

(a) What was the purpose of the audit, evaluation, or study?

(b) What were the conclusions of the audit', evaluation, or study?

(c) Who instituted the audit, evaluation, or study?

e (d) Where is the audit, evaluation, or study kept so that we can review

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12. Do Brown & Root, Texas Utilities or any of its subsidiaries or companies,

..  % 's or any of the other owners of CPSES have a public relations department

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for.the Cananche Peak plant (or if not specifically for the Ccmanche 1 Peak plant, which provide information regarding the plant)?

13 If the answer to item 12 is yes, itemize the specific companies which  !

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l have such departments and state the extent of and the type of informa-

^1on supplied by each. (For example, is there a specifio public rela-tions department for CPSES7 does a particular ccupany provide informa-

' tion as a part of its over-all public relations . department's work? ' do i

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the ccupanies, or a specific ccanpany, prepare special public relations materials specifically for the CPSES7 If so, what type of information?)

14. If the answer to item 12 is yes, supply copies of all publications or information by all such departments regarding the quality control, quality

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assurance, safety, workmanship, and method by which the plant is being builc.

15 Was there another method of documentation prior to use of deficiency and disposition reports (DDR's)?

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16. If the answer to iten 15 is yes, vhat was such method of documentation?

17 If the answer to item 15 is yes, supply copies of each and every los regarding such method of documentation.

18. Supply copies of any and all progress reports to the public, regarding l CPSES, including information provided at the CPSES infor=ation center. .

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19 Supply copies of all quality. control manuals, folders, pamphlets, and any other printed information regarding quality control, _ including procedures for quality control, not only current but the originals and

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all revirions.

20. Are there any audio tapes or video tapes of any of the information referred to in item 197 ,.

21. If the answer to item 20 is yes, where are such. tapes kept so that 'we

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can reviev.them?

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22. '

Supply copies of all quality centrol specifications manua7.s, folders, pantphlets, and any other printed information regardin6 quality control specifications, not only current but the originals and all revisions.

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23 Supply copies of all manuals, folders, pamphlets, and any other printed I

l information regarding quality assurance, quality assurance specificationa, and qaality assurance procedures, not only current but the oriEinals and all revisions. If this information has been supplied in response

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to item 19, so state.

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24. Are there any audio tapes or video tapes of any of the information referred to ivitems 22 and 237 25 If the answer to item 24 is yes, where are such tapes kept so that we can review them? l

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26. For items 14, 17, 18,19, 22, and 23, supply full-size, rather than

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reduced, copies of each.

CON'ENTION f25: .

27 Has Texas Utilities or any of its subsidiaries or companies signed

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a letter of intent to negotiate the sale of an interest in CPSES to

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Tex-La Electric Cooperativei

28. If the answer to item 27 is yes, supply ecx:iplete details of such nego-t1ations, including date of such letter of intent, copy of such letter of intent, percentage irrterest involved,' expected date of sale, expected B

value of percentage to be sold, expected sales price of percentage to be

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sold, method of' payment by buyer to Niler, and any other pertinent

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details .

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29 Has Texas Utilities or any of its subsidiaries or companies =ade over-tures to or had discussions with any other party or ccanpany to negotiate the sale of an interest in CPSES7

30. If the answer to item 29 is yes, supply c'c:plete e details (as outlined in item 28) of such overtures or discussions.

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Respectfully submitted, .

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(Mrs.) Juanita Ellis, President CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY) lh26 S. Polk Dallas, TX 75224 Dated: 7/7/80 214/946-9hh6

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• UNITED STATES OF AMERICA 'PH:q MPWMC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of -

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APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR AN I and 50-446 OPERATING LICENSE FOR COMANCHE 1 PEAK STEAM ELECTRIC STATION 1 -

UNITS #1 AND #2 (CPSES) 1

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CERTIFICATE OF SERVICE I hereby certify that copies of CASE's FIRST SET OF INTERROGATORIES TO APPLICANT in the above-captioned prceeed. ng have been served on the following by deposit in the United States : nail, first class, this 7th day of July,1980:

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Elizabeth S. Bowers, Esq., Chairman David J. Preister, Esq.

Atomic Safety and Licensing Board Assistant Attorney General U. S. Nuclear Regulatory Commission Environmental Protection Division Washington, D. C. 20555 P. O. Box 12548, Capitol Station Austin, Texas 78711 Dr. Forrest J. Remick, Member Atomic Safety and Licensing Board Mr. Richard Fouke

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305 E. Hamilton Avenue 1668-B Carter Drive State College, PA. 16801 Arlington, TX 76010 Dr. Richard Cole, Member Atomic Safsty and Licensing Board Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Nicholas S. Reynolds, Esq. Atomic Safety and Licensing Debevoise & Liberman Appeal Panel 1200 - 17th St., N. W. U. S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Marjorie Rothschild Docketing and Service Section Counsel for NRC Staff Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555

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Mr. Geoffrey M. Gay -

West Texas Legal Services 100 Main Street (Lawyers Bldg.)

Fort' Worth, TX 76102 N  %

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g$rs.) Juanita Ellis, President k

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USNRC ,3 CASE (CITIZENS ASSOCIATION FOR

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JUU101980 & - SOUND ENERGY)

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