ML20091N236

Twenty-first Set of Interrogatories & Requests to Produce to Applicants Re Response to Cygna 840330 Telcon Questions Re Allowables & Safety Factors for Richmond Inserts. Certificate of Svc Encl.Related Correspondence

ML20091N236
Person / Time
Site:	Comanche Peak
Issue date:	06/07/1984
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
OL, NUDOCS 8406120239
Download: ML20091N236 (6)

Text

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RELATED CC;GESPONDENCE T

00gaC u 6/7/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'84 JW 11 P3:37 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

<Fyu C;'us!

In the Matter of N%'iQg I

APPLICATION OF TEXAS UTILITIES I

Docket Nos. 50-445 06 GENERATING COMPANY, ET AL. FOR and 50-446 6d.

AN OPERATING LICENSE FOR I COMANCHE PEAK STEAM ELECTRIC I STATION UNITS #1 AND #2 I (CPSES)

CASE'S TWENTY-FIRST SET OF INTERR0GATORIES AND REQUESTS TO PRODUCE TO APPLICANTS Pursuant to 10 CFR 2.740b and 2.741, CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Twenty-First Set of Interrogatories and Requests to Produce to Applicants.

Please answer the following interrogatories and requests for documents in the manner set forth herewith:

1. Each interrogatory should be answered fully in writing, under oath or affimation.

2. Each interrogatory or document response should include all perti-nent infonna. tion known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel. Employees is to be construed in the broad sense of the word, including specifi-cally Brown and Root, Gibbs & Hill, Ebasco, any consultants, sub-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.

3. Each document provided should include a sworn statement of its l authenticity.

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4. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory. Do not combine answers.

5. Identify the person providing each answer, response, or document.

6. These interrogatories and requests for documents shall be continuing in nature, pursuant to 10 CFR 2.740(e) and the past directives of the Licensing Board. Because of the time restrictions under which we are presently working, we request that supplementation be made on an expedited basis.

7. For each item supplied in response to a request for documents, identify it by t'he specific question number to which it is in response. If the item is excerpted from a document, identify it also by the name of the document. Please also provide the copies in the correct order (rather than in reverse order).

8. The tenn " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, slides, internal memoranda, hand-written notes, tape recording, calculations, and any other data compilations from which information can be obtained.

CASE'S INTERROGATORIES AND REQUESTS TO PRODUCE TO ~ APPLICANTS

.All of these interrogatories and requests to produce have to do with TUGCO's response to Cygna's 3/30/84 Telecon questions regarding allowables and safety factors for Richmond inserts or questions triggered by this document.

See CASE's 6/7/8'4 letter to Michael D. Spence, President of TUGCO, pages 5 through 7. ,

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1. In regard to TUCCO's response to Cygna's 3/30/84 Telecon questions regarding allowables and safety factors for Richmond inserts (attached to the May 2,1984, letter to Cygna from L. M.

Popplewell, Project Engineering Manager for TUGCO, which was received by CASE attached to Cygna's 6/1/84 letter supplying information regarding Phase 3 of the Independent Assessment Program for Comanche Peak): What was the reason for this document's being marked FOR LAWYER'S ATTENTION ONLY NOT DISCOVERABLE

2. Where in NRC regulations is the justification for such information being "NOT DISCOVERABLE"?

3. Does the information contained in this document differ in any way from Applicants' previously stated positions in the operating license hearings?

4. If the answer to 3. preceding is yes, explain in detail such difference (s), the reasons for such differences, and why this was not called to the attention of the Licensing Board and parties in the operating license hearings.

< 5. Does the information contained in this document differ in any way from Applicants' statements or position as set forth in Applicants' 6/2/84 Motion for Summary Disposition Regarding Design of Richmond Inserts and Their Application to Support Design (received by CASE on 6/4/84)?

6. If the answer to 5. preceding is yes, explain in detail such difference (s), the reasons for such differences, and why this was not called to the attention of the Licensing Board and parties in the operating license hearings.

7. Are there any other documents which have been marked the same as, or eimilarly to:

FOR LAWYER'S ATTENTION ONLY NOT DISCOVERABLE

8. -If the answer to 7. preceding is yes, list all such documents.-

'9. ~ If the answer to 7. preceding is yes,- supply copies of all such documents.-

10. For~each document listed in response to 8. preceding, provide the following information:

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(a) Does the information contained-in this document dif fer in any way from Applicants' previously stated positions in the  ;

operating license hearings? ,

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10. (continued):

(b) If the answer to (a) preceding is yes, explain in detail such difference (s), the reasons for such differences, and why this was not called to the attention of the Licensing Board and parties in the operating license hearings.

(c) Does the information contained in this document dif fer in any way from Applicants' statements cr position as set forth in any of Applicants' Motions for Summary Disposition filed since the last operating license hearings, or from Applicants statements or position as set forth in Applicants' 4/11/84 Response to Partial Initial Decision Regarding A500 Steel?

(d) If the answer to (c) preceding is yes, identify which Motion (s) or Response it differs from, and explain in detail such difference (s), the reasons for such differences, and why this was not called to the attention of the Licensing Board and parties in the operating license hearings.

NOTE: Since this information is necessary before we can adequately respond to Applicants' Motions for Summary Disposition (especially regarding the Richmond Inserts), we ask that an expedited response be provided.

Respectfully submitted,

, jpPhrs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 J

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }{

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TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-2 and -1 COMPANY, et al. }{ and 50-446-2 and -1 (Comanche Peak Steam Electric }{

Station, Units 1 and 2) }{

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copien of CASE's TWENTY-FIRST SET OF INTERR0GATORIES TO APPLICANTS AND REQUESTS TO PRODUCE; and CASE's LETTER TO MICHAEL SPENCE, RE: BARRIERS TO SETTLEMENT have been sent to the names listed below this 7th day of June ,19 g 4 ,

by: Express Mail where indicated by

• and First Class Mail elsewhere.

• Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.

Washington, D.C. 20036

• Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission

• Geary S. Mizuno, Esq.

4350 East / West Highway, 4th Floor Office of Executive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory

• Dr. Kenneth A. McCollom, Dean -

Commission Division of Engineering, Maryland National Bank Bldg.

Architecture and Technology - Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814

• Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W.' Outer Drive- Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

• Herbert Grossman, Alternate Chairman  ;

Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Washington, D. C. 20814 1

I i

l Chairman Renea Hicks, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C. 20555 Austin, Texas 78711 John Collins Lanny A. Sinkin Regional Administrator, Region IV 114 W. 7th, Suite 220 U. S. Nuclear Regulatory Commission Austin, Texas 78701 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Michael D. Spence, President Dr. David H. Boltz Texas Utilities Generating Company 2012 S. Polk Skyway Tower Dallas, Texas 75224 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section Anthony Roisman, Esq.

(3 copies) Trial Lawyers for Public Justice Office of the Secretary 2000 P St., N.W., Suite 611 U. S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Ms. Billie P. Gsrde Government Accountability Project 1901 Que Street, N. W.

Washington, D. C. 20009 11 l s.) Juanita Ellis, President 1 ASE (Citizens Association for Sound Energy) )

1426 S. Polk Dallas, Texas 75224 214/946-9446 2

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