ML20078C963

Discusses Board Order Issued at 941004 Prehearing Conference Re Gsu/Eoi Supplemental Response to Cajun Request 2-6. Suggests That Listed Procedures Be Discussed Before Utilizing Resources of Board.Related Correspondence

ML20078C963
Person / Time
Site:	River Bend
Issue date:	10/26/1994
From:	Rudebusch T CAJUN ELECTRIC POWER COOPERATIVE, INC., DUNCAN, WEINBERG, MILLER & PEMBROKE, P.C. (FORMERLY
To:	Wetterhahn M WINSTON & STRAWN
References
CON-#494-15871 OLA, NUDOCS 9411020087
Download: ML20078C963 (2)

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'9 ADMiff t0 IN wasMINGTON ONLY BY TELECOPY Mark J. Wetterhahn, Esq.

Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005 Re: Gulf States Utilities Company, (River Bend Station), NRC Docket No. 50-458-OLA ,

Dear Mr. Wetterhahn:

In accordance with the Licensing Board's order issued >

at the October 4, 1994 prehearing conference, GSU/EOI was to supplement its response to Cajun Request No. 2-6 by identifying '

meetings between GSU and Entergy employees and identifying safety-related matters discussed at such meetings (including any 4 t

meetings concerning the SCRAM that occurred at River Bend on or about September 9, 1994).

However, neither the responses provided to Cajun on Wednesday, October 19th (under cover of Mr. Levanway's letter dated October 14, 1994), nor the related documents which we '

received on October 21, respond fully to the Licensing Board's order on these crucial issues.

GSU/EOI did provide two relevant documents on October 21, the Near-Term Performance Improvement Plan (NTPIP) and the Long-Term Performance Improvement Plan (LTPIP), and Cajun propounded follow-up discovery requests based on those documents, ,

particularly the NTPIP, on October 24, 1994. Cajun has reserved the right to conduct additional follow-up discovery, as was our right if the documents had been timely submitted on October 14. 1 Yesterday you telephoned and stated that GSU objected to Cajun's follow-up discovery conducted to date on the grounds that the requests were not likely ,> lead to the production of admissible evidence, and you indicated you would attempt to institute a telephone conference with the Licensing Board to discuss this matter. I indicated we are not opposed to a ,

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l 4 1 M.J. Wetterhaun, Esq.

8 October 26, 1994 Page 2-l telephone conference, in principle, although such a conference may be premature and unnecessary at this time.

To avoid the need for additional rulings from the l

Licensing Board on GSU's compliance with the October 4 ruling, I  ;

would suggest the following procedures: (i) GSU would complete  !

its-discovery _ responses, with Cajun having 10 days to propound l follow-up requests; (ii) Cajun will complete its follow-ups on the LTPIP by October 28th (which is within 10 days of the 21st);

and (iii) GSU will formally state its objection to any request. l At that point, which I envision to be next week (w. 5 i the possible exception of any follow-ups related to (i)], I l suggest that we sit down and discuss between ourselves how and which responses by GSU/EOI would be acceptable to both Cajun and GSU before we utilize the resources of the Licensing Board. If we cannot reach agreement on all issues, then I suggest we go to the Board with any remaining disputes.

I will telephone you later today to discuss this proposal.

Sincerely, fu j A%d _,

Thomas L. Rudebucch cc: Honorable B. Paul Cotter, Jr. (by telecopy)

Honorable Peter S. Lam ( "")

Honorable Richard F. Cole (

)

Marian L. Zobler, Esq. ( )

Robert B. McGehee, Esq. ""

( )

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