Contractor, subcontractor, or consultant, the specific

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BEFORE THE UNITED STATES

D0LKETED usNRC

NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licens'8in7gJMB1oa-2rdP5 :33

In the Matter of TEXAS UTILITIES GENERATING COMPANY,

et al.

(Comanche Peak Steam Electric

Station, Unit 1)

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CFF; '

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r,C m p.;;7 ''

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) Dkt. Nos. 50-445-CPA

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MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

(Set 5) ,

Please respond to,the following interrogatories and requests for production of documents within the time limits specified by the NRC regulations and pursuant to the requirements of those

regulations.

For purposes of this document, the following definitions and guidelines for clarifying answers are applicable:

a. " Applicants" refers to each owner of CPSES and to each

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contractor, subcontractor, and consultant. Each answer

should indicate that the answer represents the information in the possession of each and every owner and that inquiry has been made to each contractor, subcontractor, and consultant, including those no longer employed at the site, and the responses received from them, if any. In addition, when information is

obtained from an owner other than TUEC or from any

contractor, subcontractor, or consultant, the specific information so obtained, particularly documents, chould

0701050433 861230

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be identified by source whenever reasonably possible (i.e., from whom did TUEC obtain the information in

order to answer the question or request?).

b. " Documents" refers to everything ~ written or recorded in

any way, including draf ts and otherwise identical

copies of the same documents that contain substantive

additions or deletions.

c. All interrogatories and requests should be regarded as

separable and objections to portions of interrogatories

or requests do not relieve Applicants of the duty to

answer the remainder of the interrogatories or

requests. f

d. Where objections are interposed but answers given,

please indicate to what extent the answer is a complete

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response and to what extent additional information is

being withheld because of the objection.

e. Identify all documents examined, used, and/or relied

upon in answering each interrogatory.

The foregoiny definitions and guidelines are incorporated by

reference into and are a part of each of the following

interrogatories and requects.

Interrogatories (Answers due in 15 days.) 1. When did Applicants first receive notice of the issues

identified by the NRC's TRT reports and SSERs, and in what form

did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, e tc.) ?

2. For each item identified in Interrogatory 1, identify

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what response was taken to the problem and by whom.

3. If the answer to Interrogatory 2 is that no action was

taken, explain the reason that no action was taken. If that

reason is because Applicants relied on a "second opinion," identify the individuals or organizations who provided that

opinion.

4. Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by

others. (For example, how were the findings by the NRC in 1978

and 1979 integrated into Applicants' response to the findings by

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the Management Analysis Corporation (MAC) ?)

5. With referene"e to the ' attachment to the letter from

Robert A. Wooldridge to' Foster DeReitzes dated December 23, 1985, which attachment was the " work specification on the retrospective

audit," please answer the following questions:

a. What is the current status of that audit, and why is it

being conducted?

b. To what extent have the work specifications been

changed; what are the changes; who changed them; and why? c. When will the audit be completed?

d. Why was the completion of the audit originally tied to a

date shortly before anticipated fuel load of Unit 17

,

e. Is it still tied to a date shortly before fuel load of

Uni t 1, and, if so, why?

f. What types of documents have been generated in the

course of conducting the audit? Please include within your

answer handwritten notes, internal memos within the

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organization (s) conducting the audit, progress reports to Appticants on the audit, minutes of meetings and notes by participants in meetings among the auditor personnel or between the auditors and any other persons.

9 Has the audit or any of the audit personnel reached any tentative or final conclusions on any subjects? If so, what are those conclusions?

h. Who is conducting the audit, and who at TUEC is

supervising the conduct of the audit?

Request for Production of Documents

(Answers due in 36~~ days.)

1. With referencp to page 2 of Mr. Beck's letter to the

mnority owners dated July 31, 1985, please provide a copy of the

"Dreakdown of the 1978 MAC report findings to identify which items have been resolved by the project and which are being further addressed by the CPRT ef fort."

2. With reference to Interrogatory 5, please provide a copy

of all the documents the types of which are described in

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Interrogatory 5.f.

3. With reference to Interrogatory 5, please provide a copy of all documents that define the nature of the audit and the relationship between TUEC and the auditors, including all

contracting documents. Portions of the documents that disclose the actual price of the work to be performed need not be

disclosed.

4. Produce the original or copies of all documents in

Applicants' custody, possession, or control that were examined,

used, and/or relied upon for answering Interrogatories 1 through

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S above. If a document has already been supplied in this docket or in the OL docket, Applicants may identify with particularity the location of the document or answer by including the name of the document, page and line number, in which docket the document was produced, and the date it was produced. This does not apply if the answer previously provided was an objection. In that case, Applicants must reassert the obbjection to the extent

applicable to this proceeding.

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Dated: December 30, 1986

Respectfully submitted,

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ANTHONY Z. KIdpN

Trial Lawy fs for Public Justice

2000 P S eet, NW, #611

Washington, D.C. 20036

(202) 463-8600

Counsel for Meddie Gregory

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