ML20133Q129
| ML20133Q129 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/12/1985 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Citizens Association for Sound Energy |
| Shared Package | |
| ML20133Q132 | List: |
| References | |
| CON-#385-216 OL, OL-2, NUDOCS 8508150029 | |
| Download: ML20133Q129 (18) | |
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DCLKETED ushRC In the Matter of :
- Docket Nos. 50-445 85 AUG 13 - All :42 TEXAS UTILITIES ELECTRIC : 50-446 COMPANY, ET AL. : 50-445-2 GFFIC:. GF HC6
- 50-446-2 COCdlishG4 SE8 6 (Comanche Peak Steam Electric : BRANCH Station, Units I and 2) :
APPLICANTS' RESPONSES TO CASE'S INTERROGATORIES RE: THE MAC REPORT AND ISSUES RAISED BY THE MAC REPORT Pursuant to 10 C.F.R. Sections 2.740b and 2.741, Applicants hereby provide their responses to CASE's Interrogatories in connection with the MAC Report and issues Raised by the MAC Report dated June 24, 1985. Applicants' responses are governed by the Memorandum and Order entitled " Memorandum (Motions Relating to the MAC Report)" dated July 22,1985.
- i. On page 2 of Applicants' 5/29/85 cover letter, it is stated that the MAC Report was discovered "in gathering data for a prudence audit being performed for TUEC," and other relevant details are given.
Provide the following regarding such prudence audits (a) What company / companies or organization (s) is/are performing the pru-dence audit?
Answer Cresap, McCormick & Paget.
(b) Provide the name (and company / organization and title) of each indi-vidual who is performing such prudence audit for the company /organi-zation in (a) preceding.
Answer: There are a number of individuals working for Cresap, McCormick & Paget on the audit. A list of these individuals is attached.
(c) What organizations affiliated with Applicants (TUSI, Brown & Root, Ebasco, PSE, etc.) are involved with such prudence audit, and what is the extent of their involvement?
Answer: The audit is being performed solely for Texas Utilities Electric Campany. Other firms have personnel who have been (b $00$
ha >
o 2 interviewed and/or have responded to questions posed by Cresap, McCormick & Paget, but only Texas Utilities Company sub-sidiaries are being audited by the Cresap firm.
(d) Provide the name (and organization and title) of each individual with each of the organizations m (c) preceding who is primarily or actively involved with such prudence audit.
Answer: Applicants object to this Interrogatory and also to Inter-rogatories 1.(f),1.(m), and 1.(s) for the reason that each of said Interrogatories inquires in detail as to matters which have ab-solutely nothing to do with the MAC report, are wholly outside the scope of these licensing proceedings and such inquiries con-stitute a fishing expedition for material related only to CASE's participation in Applicants' rate cases before the Texas Public Utility Commission. Same is, therefore, not a legitimate purpose for discovery pursuant to 10 C.F.R., Section 2.740b. In this connection, Applicants would refer the Board and the Intervenor to answers to Interrogatories 1.(e) and 1.(k) below for an ex-planation of the purpose of such prudence audit. Such audit has no bearing upon the discovery of the MAC Report. The Report was found by Appilcant, and not by the auditing firm. The only reason the prudence audit was even mentioned was to explain why Appilcant happened to be inspecting files. To permit, therefore, the Intervenor to engage in discovery on such wholly unrelated matter contrary to the purpose and intent of this Commission's -
rules and to the prejudice of Applicants and other parties who may be involved in rate cases before the Texas Public Utility Commission is wholly unjustified and unnecessary and should not be permitted by this Board.
-(e) What is the purpose of such prudence audit?
Answer: The purpose of the audit is to provide an independent third-party evaluation of the economic effect of management decisions on the total cost of the Comanche Peak project.
(f) Who (name, organization, title) determined the purpose and scope of such' audit? If such Individual (s) consulted with others, provide the name, organization, and title of each such person. Include in your answer a brief discussion of how it was decided that such an audit was 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).
l Answer: See objection contained in answer to Interrogatory 1.(d)
- above.
(k) For what purpose (s) will the prudence audit be used by Applicants?
!. Answer: It may form a part of TUEC's testimony in any rate case to l
' consider the rate-making treatment of Comanche Peak "as above described.
l (m) Which other audits, reports, analyses, etc., were reviewed or will be reviewed by prudence auditors in connection with the prudence audit?
i f
, ,f Answer: See objection contained in answer to Interrogatory 1.(d) above.
(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 drafts of the prudence audit, as well as the final prudence audit itself.
Answer: See objection contained in answer to Interrogatory 1.(d) above.
- 2. (a) Specifically who (name, organization within TUGCO, title) made the
" search . . . of inactive and closed corporate files located in TUGCO's Dallas office"? Whose (specifically, both now and at any time pre-viously) office was the report in?
Answer: Mr. Andrew S. Jones, senior auditor employed by Texas Utilities Services Inc. The report presently is in the possession of counsel for the Company, Mr. Robert A. Wooldridge. At the' time it was found, it was located in a storage box in the TUGCO corporate offices on the 31st floor of Skyway Tower. It tem-porarily was being stored in the office of Mr. Homer Schmidt, but was not actively maintained by Mr. Schmidt.
(b) Specifically who (name, organization / company, title, duties and re-sponsibilities) first identified the MAC Report as being a document which Applicants should have provided in response to CASE's 1980 discovery requests?
Answer: Mr. Robert A. Wooldridge, an attorney representing the Applicant.
(c) Provide a summary of exactly when, how and by whom the MAC Report was found and the process by which the determination was made that Applicants should have provided it in response to CASE's 1980 discovery requests. Include specific details as to exactly when each action or event occurred, who (name, title, organization at the time, current title and organization) was involved, etc.
(The type of information we want includes something like: Auditor ,
(name) with (name) company asked to see all management audits which had been performed regarding Comanche Peak. Secretary (name) brought the auditor a stack of files for review. Auditor (name) indicated that he/she wanted a copy of the MAC Report and/or that
. he/she planned to consider and include it in the prudence audit.
(Name), TUGCO (title), and (names) were present at the time Auditor 1
(name) gave such indication. (Name), TUGCO (title) realized that the MAC Report should have been provided to CASE on discovery in 1980,
! and informed (name, title, organization), who informed (name of attorney, law firm) on (date).
j Answer: The MAC Report was located by Mr. Andrew S. Jones in late
- April,1985, while he was surveying the contents of the inactive l and closed corporate files stored in Mr. Schmidt's office. He was
.. =- _ _ - . . . - _- , -
- looking for information relevant to the prudence audit. Mr. Jones mentioned the MAC Report to Mr. Robert Spangler and Mr. Dave
- Chapman during a discussion of Q.A. Issues related to the prudence audit. Mr. Chapman informed Mr. Jones that there- l 2
tofore the document had been kept confidential and that Mr.
Jones should review the report with TUGCO management before making it available to the Cresap firm. Mr. Jones then delivered the report to Mr. Tom Rose. Mr. Homer Schmidt, Mr. Rose's supervisor, reviewed the document and suggested that the matter should be reviewed by Mr. Wooldridge to determine whether the report should be made available to the auditors. On or about May 10, 1985, the audit report was deli ered to Mr. Wooldridge, who reviewed the same shortly thereafter. Mr. Wooldridge then discussed the matter with Mr. Chapman and reviewed the prior l discovery requests of CASE in the ASLB proceedings to determine whether the MAC report was within the scope of those requests.
(d) Provide the exact extent of knowledge (attended initial interview 4
regarding MAC Report, attended pre-audit meeting, attended post-audit meeting, received copy of report, knew about report, participated i
in internal management discussions regarding report, was aware report should have been provided to CASE on discovery, was interviewed by Mr. Wooldridge "in order to determine why the report was not produced in 1980 in response to CASE's first discovery request," etc.) of each of the individuals listed below.
(If the extent of his/her knowledge changed, give specific details as to how, why, in what way, and at what time such change occurred.)
D. N. Chapman R. G. Tolson R. V. Fleck
- 3. V. Hawkins
- 3. B. George
- 3. T. Merrit(t)
E. G. Gibson B. 3. Murray
- 3. 3. Moorhead B. C. Scott
- 3. P. Clarke R. Mann H. O. Kirkland U. D. Douglas D. C. Frankum P. Foscolo L. Hancock A. Boren A. Vega C. Beggs R. Gary (Fikar)
L. Fiker P. Brittain Michael Spence John Marshall 4
Susan Spencer Homer Schmidt Thomas Brandt Gordon Purdy John Beck Other Brown & Root personnel (list each)
Anyone with the minor owners of Comanche Peak or their agents, consultants, etc. (!!st each)
Any of Applicants' new (since January 1984) consultants, em-ployees, or agents (list each individual, his/her title and organi-zation)
Answer: The following persons (upon information presently available to Applicants from interviews) had no knowledge of the MAC audit, the report, or discovery relating to the report, until the time mentioned in paragraph 2(c) above, i.e., May or June,1985:
Michael Spence, John Beck, Homer Schmidt, Tom Brandt, Gordon Purdy, the minority owners, and Applicants' new consultants, em-ployees, agents.
Regarding the extent of knowledge of others mentioned in Inter-rogatory 2(d), see the answer to paragraph 2(e) below and the affidavits attached.
(e)
For each of the individuals in (d) above who had any knowledge of the MAC Report, provide the following informations (1)
Specifically when did he/she first find out about the MAC ReportT If the extent of his/her knowledge changed, specifically when did each such change occur?
(2) How did he/she first find out about the MAC Report?
(3) Title and organization at time he/she first found out about the MAC Report; title and organization as of December 31, 1984; title and organization at present; date of each change in title and/or organization between December 31,1984 and the present.
(4)
If no longer employed by Applicants or their agents, provide his/her last known home and business addresses and telephone numbers.
(5) Provide a sworn affidavit by each Individual that the statements in your answer are true and correct.
(6)
Make each individual listed in (d) above or your answer to (d) above available for CASE to take his/her deposition.
Answer: See the affidavits attached to this response.
Applicants were unable to locate J. J. Moorhead (believed to be in Saudi Arabia), R. V. Fleck (believed to have last been employed by Florida Power & Light), and R. Mann (lef t CPSES in July of 1978).
~~
s .,
Applicants were unable to obtain a statement or affidavit from !
the following individual: H. O. Kirkland.
Affidavits are expected to be received from J. P. Clarke, Feter Foscolo, and I.ee E. Hancock but were not available for fillrg on this date. This answer will be supplemented when the affidavits are received. '
Regarding paragraph 2(e)(6), Applicants will consider a reascnable formal request, if necessary, and in accordance with the Com-mission's Rules of Practice, as to specific depositions. Applicants i expressly reserve the right to file objections and motlans in response thereto.
(f) (1) When the MAC Report was first received by App!! cants la 1978, what distribution was made of it; who received copies of it?
Answer: Same was received by App!! cants on or about the 14th day of May,1978. Copies were made available to Messrs. 3rittain, Pikar, Gary, and those individuals who have stated they also received a copy of same in the affidavits attached. A;911 cants are not aware of any others receiving a copy.
(f) (2) Were copies of the Report distributed to others at a later time?
If so, give specific and complete details as to who, when, etc. l Answer: Not to App!! cants' knowledge.
(f) (3) ' What happened to each copy of the report in your answers to (1) and (2) above? Did the Individual still have a copy at the time the i report was rediscovered during the prudence audit? Did anyone (Mr. Fikar, for instance) confiscate the other copies of the l Report? If so, provide specific and complete details as to who, when,, etc.
Answer report which was located by Mr. Jones had originally been the file of Mr. Brittain, who was then the President of TUGCO. Such co>y was still in the TUCCO files at the time it was found. Mr. Ficar also had a copy of the report in his office. ,
Both Mr. Gary and Mr. Chapman had copies initially, in 1978, but !
they did not retain them. See the affidavits attached. No copies of the report were " confiscated" by Mr. Fikar.
(f) (4) Did anyone (Mr. Fikar, for instance) order the other Individuals l who were aware of, or had copies of, the Report not to supply l them to CASE on discovery or not to advise Applicants' counsel of '
the Report's exis6ence? If so, provide specific and complete details as to who, when, etc.
Was there any discussions between or arnon
, and/or any others listed in (d) or your answer topreceding (d) g Mr.asFikar I to whether or not the Report should be supplied to CASE on l discovery? If so, provide speelfic and complete detalls as to who, i when, the result of such discussions, etc. ,
Answer Not to Applicants' knowledge, although Mr. Fikar, we be. l lieve, made the deelslon that the MAC report was proprietary and !
l !
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should not be disclosed in response to CASE's discovery request in this proceeding. Such decision was made known to Mr. John Marshall and possibly to others. See affidavits attached.
(f) (5) To whom specifically (name, organization, title, responsibilities) was Mr. Wooldridge referring when he stated that "TUGCO management is evaluating the failure to produce this document at an earlier time . . ."?
Answer: At the request of Mr. M. D. Spence, Mr. Wooldridge continued to have discussions with the various personnel invct' ed.
(f) (6) To whom specifically (name, organization, title, responsibilities) was Mr. Wooldridge referring when he stated "We determined that the report was subject to discovery"?
To whom specifically (name, ceganization, title, respon-sibilities) was Mr. Wooldridge referring when he stated " current TUGCO management concurred in that view"?
Answer: With the assistance and advice of Mr. Wooldridge, Mr.
Spence determined that the report should be produced. Other members of the current Texas Utilities management that con-curred in that view were Messrs. Perry G. Brittain, William Counsil, and John Beck.
(f) (7) Specifically who (name, organization, title, responsibilities) did Mr. Wooldridge interview "At the direction of Mr. Spence . . . to determine why the report was not produced in 1980. . ."?
Answer:
Mr. Spence did not direct Mr. Wooldridge as to who he should Interview.
l Mr. Wooldridge has interviewed, in alphabetical order, the following lj individusts, relating to the MAC report:
Debra Anderson, Texas Utilities Generating Company John Beck, Texas Utilities Generating Company Tom Brandt, Ebasco Services Perry G. Brittain, Chairman of the Board and Chief Executive, Texas Utilities Company Dave Chapman, Texas Utilities Fuel Company B. R. Clements, Vice President, Texas Utilities Generating Company L. F. Fikar, Executive Vice President, Texas Utilities Generating Company R. J. Gary, Executive Vice President, Texas Utilities Generating Company Joe B. George, Texas Utilities Generating Company 7
Andy Jones, Tcxas Utilitics Gener ting C:mp:ny John Marshall, Texas Utilities Generating Company John Merritt, Texas Utilities Generating Company Susan Spencer Palmer, Texas Utilities Generating Company Nicholas S. Reynolds, attorney for Applicants Tom Rose, Texas Utilities Generating Company Homer C. Schmidt, Texas Utilities Generating Company Robert Spangler, Texas Utilities Generating Company Michael D. Spence, President, Texas Utilities Generating Company Ron Tolson,1114 Briarbrook, DeSoto, Texas 75115 Antonio Vega, Dallas Power & Light Company (f) (8) Specifically who (name, organization, title, responsibilities) were the "few members of company management" whom Mr. Fikar believed the report was solely prepared for?
Answer: Messrs. Brittain, Pikar, and Gary.
(f) (9) Applicants' 6/12/85 letter stated: "Mr. Fikar further stated that he thus believed that his decision not to produce the report was justified. No advice of counsel was obtained at the time regarding the discoverability of the report."
When did Mr. Fikar seek advice of counsel?
Provide details of how, when, by whom (name, organization, title, responsibilities), under what circumstances, Appilcants' counsel first became aware of the Report. Who specifically of Applicants' counsel was first informed of the Report?
Answer: To Applicants' knowledge, Mr. Fikar had not sought advice of counsel regarding this report at any time prior to the time Mr.
Wooldridge first interviewed him regarding same in mid-May, 1985.
Regarding the inquiry concerning when Applicants' counsel first became aware of the report, see answer to 2.(c) above. Mr.
,, Wooldridge was not aware of the report until on or after May 10, 1985. Mr. Reynolds was not aware of the report until Mr.
Wooldridge advised him of same.
(f) (10) Applicants' 6/12/85 letter states that the Interviews indicated or revealed that Messrs. Fikar, Clements, Chapman, and Tolson were aware of the report, and provides some detail about the extent of such awareness.
Did Messrs. Fikar, Clements, Chapman, and/or ', mon pro-vide the information about his own awareness, or wa the infor-mation obtained through interviews with other Individo. 'M r
Answer: Mr. Wooldridge interviewed Messrs. Fikar, Clements, Chapman, and Tolson. The statements attributed to them were provided by those individuals.
(f) .(11) Provide a comparison of the time frame when the MAC Report was rediscovered during the prudence audit to the time when recent changes were made in management (specifically, but not limited to, Messrs. Fikar, Clements, Tolson, Vega, Chapman, Purdy).
Did any of the changes in management occur as a result of the rediscovery of the MAC Report?
^ Were any of the changes in management made in whole or in part as a disciplinary measure? .
J-Were any of the individuals whose positions were changed or j
who were involved in recent management changes offered the i option of resigning, retiring, being reassigned to other duties, and/or having disciplinary action taken?
Provide specific and complete details, regarding each Indi-
) vidual.
, Answer: The MAC report was found subsequent to the changes in
- management which have involved Messrs. Tolson, Vega, and Chapman, and subsequent to the time of Mr. Fikar's reassignment to non-nuclear activities. The report was discovered prior to Mr.
Fikar's retirement, Mr. Clements' reassignment, and Mr. Purdy's decision to resign from Brown & Root.
Mr. Purdy's decision was not related to the MAC report. Mr.
i Fikar made the decision to request early retirement following a conversation among he and Messrs. Spence and Wooldridge, which conversation involved the discussion of the circumstances sur-rounding the disclosure of the MAC report. Mr. Clements' reassignment, in part, related to his failure to insist upon a i reconsideration of Mr. Fikar's decision to not disclose the report. *
' Regarding the " offering of options" to these individuals, no such options were discussed.
(f) (12) Were all " inactive and closed corporate files" reviewed in con-nection with the prudence audit?
- If so, what else was found which may be discoverable?
, If not, provide them or access to them for inspection and
- copying.
? (f) .(13) Do similar active or inactive / closed corporate files exist at TUSI, TUEC, TU, DP&L, TP&L, TESCO, minor owners of Comanche Peak, and/or TUGCO's offices (either in Dallas, other offices, or j at the plantsite)?
l 1
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If so, answer all applicable questions herein regarding those files.
, If your answer is that you don't know, provide them or i access to them for inspection and copying.
Answer to 2.(fX12) and 2.(fX13):
In the Board's Memorandum and Order (Motions Relating to the MAC Report) dated July 22, 1985, these interrogatories are stricken to the extent that they are "not responsive to outstanding discovery requests." All of the closed files which were in Mr.
Schmidt's office were reviewed and will be reviewed again as part of the Plan for Inspection of Files, attached. Applicants are not aware of any documents, other than the MAC report, whether in those files or elsewhere, which would be responsive to outstanding i
[ discovery requests that have not previously been produced.
, 3. (a) Applicants' 6/12/85 letter stated: ". . . Applicants are taking steps to j assure that no other such documents exist and to assure that a similar situation does not recur."
Specifically what steps are being taken in this regard, and by whom (name, title, organization) are they,being taken?
Answer: Mr. John Beck, as the TUGCO officer responsible for licensing, has initiated a program of review of documents. A description of such program entitled Plan for Inspection of Files is attached.
I (b) Applicants' 6/12/85 letter stated: "We also will reiterate Applicants'
, obilgations in this regard to those who have responsibility to provide information to the NRC and to the parties."
(1) Who specifically will reiterate App!! cants' obilgations in this regard?
(2) Who specifically (name, title, organization) currently has
- " responsibility to provide information to the NRC and to the 4
parties"?
(3) Who specifically (name, title, organization) in the past had
" responsibility to provide information to the NRC and to the parties"? Specify the time frames during which each such individual had such responsibility.
1 (4) What is the current criteria for determining whether or not documents would be provided to CASE on discovery?
(5) What were the former criteria for determining whether or not documents will be provided to CASE on discovery?
z (6) What is the current criteria for determining whether or not the ;
NRC (both the Staff and the Licensing Board) will be advised of the existence of, or provided copies of, documents?
j i
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(7) What were the former criteria for determinin NRC (both the Staff and the Licensing Board)g whether would be advisedorof'not the the existence of, or provided copies of, documents?
(8) Specifically who (name, title, organization, duties) decided upon such criteria (both past and present)?
(9) How do management reviews and/or audits, QA reviews and/or audits, etc., which are performed by consultants (as opposed to being part of Applicants' formalized internal and/or vendor auditing system) fit into Applicants' overall system of quality assurance / quality control? Include in your answer (but do not limit your answer to) the following:
(1) How and where are reports / audits such as this filed and kept? (Answer for both past and present practices /
procedures.)
(ii) By whom (name, title, organization) are such reports / audits ,
kept? (Answer for both past and present.)
(iii) What is the system of filing and distributing such reports
/ audits? (Answer for both past and present.)
(iv) Provide a copy of the distribution !!st (all past and present lists) for such reports / audits.
(v) How are the findings and concerns of such reports / audits trended? (Answer for both past and present.)
(vi) Provide copies of all such trending summaries /re-ports / analyses, etc.
(vii) 15/was there a listing (computerized or otherwise) of all such reports / audits?
If so, provide a copy of all such listings.
If not, by what means are such reports / audits tracked or kept up with? What assurance is there that there are not other such reports / audits which should have been, but have not been, supplied on discovery to CASE 7 (viii) Were, or are, such procedures / practices / criteria pro-ceduralized?
If so, provide copies of all sJch procedures (past and present).
If not, what assurance is there that such procedures were or will be followed consistently?
Answer:
~ In its Order of Jul described above, the Board struck Interrogatory 3.(b)y .
22,1985, However, App!! cants were directed to state in appropriate evidentiary form precisely the actions they will take to " reiterate App!! cants' obilgations."
Mr. Spence has requested that Mr. Wooldridge develop a program to make sure that those who are responsible for collecting and responding to discovery requests are aware of the Applicants' obligations relating to such discovery. Mr. Wooldridge, or Mr.
Reynolds, or one of the members or associates of their firms, will be responsible for assuring that those persons responsible for collecting or gathering data or information are aware of the NRC Rules of Practice and NRC decisions relating to discovery re-quests and know that any request for information not objected to and upon which an objection has not been sustained is to be provided in accordance with each specific document request.
These persons will be instructed that to resolve any possible doubt about discovery, any question regarding the discoverability of any document which might be considered to be proprietary or con-fidential is to be brought to the attention of Applicants' counsel for review.
- 4. (a) Whose handwritten notes are shown in the margins of the MAC Report?
Answer: Mr. P. G. Brittain's.
(b) When were such notes made?
Answer: The notes were made shortly after receipt of the audit report in 1978.
(c) The handwritten notes on CASE's copy of the MAC Report were not '
clear, and in some instances were run so that part of the notes were off the page.
Provide good, clear copies of all pages with handwritten notes.
Answer: See attached for another copy of the report.
{pk
- 6. Provide any and all documents (in the broad sense of the word, as defined on page 2, item 3, of this pleading) relating to all of your answers to questions 1 through 5 preceding.
Answer See objection as to documents requested under Question 1.
Such other documents are available for review in the offices of Mr. Robert A. Wooldridge,2001 Bryan Tower, Suite 2300, Dallas, Texas 75201.
Respectfully submitted, Nicholas S. Reynolds William A. Horin BISHOP,1.lBERM AN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.
Suite 700 Washington, D.C. 20036 (202) 337 9800 12
Thomas G. Dignan, Jr.
R. K. Gad, III ROPES & GRAY 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Robert A. Wooldridge WORSHAM, FORSYTHE, SAMPELS
& WOOLDRIDGE 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 (214) 748-9365 By f Robert A. Wooldridge Counsel for Applicants I
.u.
AFFIDAVIT THE STATE OF TEXAS :
COUNTY OF DALLAS :
Before me, the undersigned authority, a Notary Public in and for Dallas County, Texas, on this day personally appeared P,OBERT A. WOOLDRIDGE, who, after being by me first duly sworn, upon his oath stated that he is attorney for Applicants, is authorized to reply to CASE's Interrogatories Re: The MAC Report and Issues Raised by the MAC Report on behalf of the Applicant, and further stated that, to the extent the responses to these Interrogatories refer to state-ments made by others, he has relied upon such statements and the Affidavits attached to these answers, and that he has no reason to believe that any of the statements are untrue and that insofar as the answers to Interrogatories refer to actions taken by him personally, said answers are true and correct.
/
/dH ROBERT A. WOOLDRIDGE
- L SUBSCRIBED AND SWORN TO before me by the said ROBERT A.
WOOLDRIDGE on this, the MTM day of August,1985.
W 5%
Ndtary Rblic in and for Dallas County, Texas My Commission Expires:
. 'I-\ 4 on 14
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of. : Docket Nos. 50-445-1
- 50-446-1 TEXAS UTILITIES ELECTRIC : 50-445-2 COMPANY, ET AL. : 50-446-2 (Comanche Peak Steam Electric : (Application for Station, Units 1 and 2) : Operating Licenses)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Responses to CASE's Inter-rogatories Re: The Mac Report and Issues Raised by the MAC Report" in the above captioned matter were served upon the following persons by express mall (*) or by hand delivery (**) or by Federal Express (***) on the 12th day of August,1985.
Mr. Peter B. Bloch, Esq., Chairman ***
Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom***
Administrative Judge Dean, Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74078 Elizabeth B. Johnson ***
Administrative Judge 4
Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 f
Dr. Walter H. Jordan ***
Administrative Judge
, 881 W. Outer Drive Oak Ridge, Tennessee 37830
- Mrs. Juanita Ellis*
President, CASE 1426 South Polk Street i
Dallas, Texas 75224
, Renea Hicks, Esq.***
! Assistant Attorney General Environmental Protection Division
- P. O. Box 12548, Ca sitol Station Austin, Texas 7871t
.l.
Nicholas S R:;ynolds, Esq ***
Willirm A. Horin, Esq.
Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.
Suite 700 Washington, D.C. 20036 Mr. Michael D. Spence, President **
Texas Utilities Generating Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Thomas G. Dignan, Jr.***
Mr. R. K. Gad, III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Robert D. Martin **
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin*** '
3022 Porter Street, N.W., #304 Washington, D.C. 20008 Chairman ***
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William L. Clements***
Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stuart A. Treby, Esq.*** ,
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman ***
Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Ellen Ginsberg, Esq.***
U.S. Nuclear Regulatory Commission 4350 East / West Highway,4th Floor Bethesda, Maryland 20814 Geary S. Mizuno, Esq.***
Office of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Bldg., Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Herbert Grtssman, Alt;rn:ta Chairman ***
Administrative Judge Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Billie Pirner Garde ***
Citizens Clinic Director Government Accountability Project 1901 Que Street, N.W.
Washington, D.C. 20009 Anthony Roisman, Esq.***
Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D.C. 20036 Joseph Gallo, Esq.***
Isham, Lincoln & Beale 1120 Connecticut Ave., N.W.
Suite 840 Washington, D.C. 20036 7 ?
!h htw a Robert A. Wooldridge
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l' CRESAP, MCCORMICK AND PAGET Staff Involved In Retrospective Audit Of CPSES Name '
Title Jeff Schmidt Vice President Bruce Pittenger Vice President Len Wass Vice President Garry Dietz Managing Consultant Ned Sickle Managing Consultant Greg Presely Managing Consultant Jim Sullivan Consultant Steve Brauer Consultant Bob Cornick consultant Marshall David Consultant John Dolan Consultant Joel Elliott Consultant Tom Fleming Consultant Andy Patterson Consultant Clay Press Consultant Bart Rocca Consultant Dob Shields Consultant Tom Jackson Consultant -
Tom Davenport Consultant
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