ML20071L012

Confirms 820715 & 28 Conversations Re Intervenor 820628 Motion to Compel Discovery on Interrogatory 27 in 820604 Nineteenth Set of Interrogatories

ML20071L012
Person / Time
Site:	Clinch River
Issue date:	07/28/1982
From:	Finamore B National Resources Defense Council
To:	Edgar G MORGAN, LEWIS & BOCKIUS
References
NUDOCS 8208020300
Download: ML20071L012 (2)

Text

. . .

Natural Resources Defense Council,Inc.

POLN 17 5 I STREET, N.W.

SUITE 600. ..,

WASHINGTON, D.C. 2000 6 { i b d' som s23-821o New York opce 7, .- G7 Vktern 0$ce j

zAsr quNo srRzar July 28, 1982 M %[)d,B e5 KEARNY STR '

NEW YORE, N.Y.10168 SAN FRANCISCO, CALIF. g(108 sta 949-0049 4:54:1-656:

. . l^ a George L. Edgar, Esq. -

Morgan, Lewis & Bockius ~q 1800 M Street, N.W.

Washington, D.C. 20036 DOCKET IW

.FROD. & UN

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Dear George:

This letter is to confirm our conversations of July 15 and July 28, 1982 concerning Intervenors' June 28, 1982 Motion to Compel Discovery on Interrogatory #27 of Intervenors' Nineteenth Set of Interrogatories (dated June 4,1982) . The Board denied this motion June 30, 1982 because the parties had not conferred directly before the motion was filed. However, the denial was "without prejudice to filing a motion that com-plies with prior discovery orders." Order at 2.

I conferred with you on July 15, 1982 to determine whether Applicants would provide a complete and direct answer to Inter-rogatory #27. We agreed that the term "probabilistic analyses of CRBRP accident risks and/or consequences" used in that interrogatory refers to any quantitative probabilistic or quantitative reliability data of CRBRP accident risks and/or consequences. You indicated that you would confer with Appli-cants and let me know whether Applicants would provide a complete and direct answer to Interrogatory #27.

When two weeks went by without an answer, I called you again on July 28, 1982. You stated that Applicants would supple-ment Interrogatory 427 within this week or next. You said that the supplementary answer would state that, given the definition of Interrogatory #27 agreed to by the perties on July 15, 1982, Applicants had not yet determined what probabilistic analyses they intended to rely upon during the LWA-1 proceeding. I noted that it should be possible to provide a supplementary answer i sooner than next week if the answer stated only that Applicants had not yet made the requested determination. You said that an earlier response was not possible. You also stated that it will 8208020300 820728 PDR ADOCK 05000537 C PDR Ners England Ogice: 17 Erie nRivE

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George L. Edgar, Esq.

July 28, 1982 Page Two be several weeks before applicants will be able to determine which CRBR probabilistic risk analysis they intend to rely upon during the LWA-1 hearings.

Sincerely, 9

W /7 fW Barbara A. Finamore ,

Counsel for Intervenors Natural Resources Defense Council, Inc. and the Sierra Club cc: Service List h

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