ML20039E901
| ML20039E901 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/07/1982 |
| From: | Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Falk K WISCONSIN'S ENVIRONMENTAL DECADE |
| References | |
| NUDOCS 8201110599 | |
| Download: ML20039E901 (3) | |
Text
_ _ _ _ _ _.
- s..,
5 g-p (W
J
+
January 7,1982
' ' pg&
v 4
(J SFJO V
Kathleen M. Falk, Esq.
M Wisconsin's Environmental Decade
~
.s 114 ilorth Carroll Street, Suite 208 C
- 7 t.
Madison,llI 57303
(
,~
A d
/..
'b/[] ] (\\P In the Matter of Wisconsin Electric Power Company (Point Beach fluclear Plant, Units 1 and 2)
Docket flos. 50-266 & 50-301
Dear lis. Falk:
This letter is to confirm my telephone discussion with your associate, lir. Peter Anderson, on January 6,1982. That discussion was prompted by my telephone call to you on January 5,1982, concerning 111sconsin's Envi-ronmental Decade's December 21, 1981 answers to the Staff's interrogatories which were filed on December 2, 1981.
The discussion with Mr. Anderson was in accordance with the Licensing Board's guidance that parties should make reasonable attempts to resolve differences in direct discussions.
Instead of now filing a motion to compel answers to the interrogatories which the Staff believes were not properly responded to, I will await the supplement to Decade's answers, which Mr. Anderson committed to provide.
The Staff does not waive its right to file a motion to compel responsive answers to its interrogatories in the event the supplemental information does not comply with the agreenent between mysel f and tir. Anderson.
Each original Staff interrogatory is set forth below, with my under-standing of Decade's obligation or clarification of position.
1.
Within the Board's broad contention, state the particular issues which llED intends to 1"igate in this proceeding, and identify the factual basis for each issue.
Decade will provide the Staff a comprehensive, self-coni. dined list of the issues it now intends to litigate.
Each issue will be accompanied by Decade's specific basis for that issue at this point in the proceeding.
2.
State the names, address and professional qualifications of the person or persons upon whose views WED relies to substantiate each issue, identified in response to Inter-pg)]
f.....
8201110599 820107
/..O om>
PDRADOCK05000g 0
Ec row am one,wcu mo OFFICIAL RECORD COPY
- = +3m
.hay
,. rogatory 1, and/or whom WED will present as an expert witness as hearing.
At this time. Decade has no experts upon whose views it relies or whom it will present as witnesses. No further response is necessary at this time.
3.
State by author, title, date of publication and publisher all books, tests and papers upon which each person named in the response to Interrogatory 2 and WED relies to sub-stantiate his or her views.
Decade will identify, and make available to the Staff, specific documents frau the Public Service Commission of Wisconsin proceedings, which Decade currently intends to rely upon in presenting its case.
Decade avers that no document, not already specifically identified in this proceeding by Decade will be eclied upon without notifying the other parties.
4.
Describe all independent calculctions, physical and mathematical models upon which each person named in Interrogatory 2 or WED relies to substantiate that person's views.
5.
Provide summaries of the views, positions or proposed testimony of each person in Interrogatory 2 whom WED will present as an expert witness at hearing.
No response is necessary at this time, since as noted in 2. above, Decade has no experts, as witnesses or otherwise, at the present. Also, Decade avers no independent calculations, physical or mathematical models now exist.
6.
State by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of pro-spective NRC Staff witnesses testifying in connection with each issue.
No response is necessary at this time.
Decade has not yet compiled the material to be used in the cross-examination of Staff witnesses.
This compilation will be done after the issuance of the Staff's SER and EIA, and the parties will be informed.
Finally, as a general matter, Decade is aware of its duty pursuant to 10 C.F.R. 5 2.740(e) seasonably to supplement its responses.
a"'c4 uc row 3,e no,.o unc""
OFFICIAL RECORD COPY
+ = =-32"
m es ews
~m mcar vr/y 1&
M,
,e <?
4 ny s' 3 g
.g g.
45 g
g ps-Please promptly advise me if, in your view, this letter does not reflect Decade's agreement (by Mr. Anderson) with the Staff.
Sincerely, Richard G. Bachmann Counsel for ilRC Staff cc: Service List DISTRIBUTION:
RGBachmann l
CABarth SATreby l
MKarman l
S/E C/0/S l
ELD FF (2)
TColburn l
DMB PDR/LPDR Chron I
t i
omer >I OELD cum = > R cbmaon:.a s....S ATr
(....
01 cur)..... /.07/.82...
01
..../.0 7/.8 2...
N5C FORM 31H t10e80l NRCM O240 OFFICIAL RECORD COPY
.w#o mo-32n2.