ML20094J898
| ML20094J898 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/13/1984 |
| From: | Roisman A TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Belter L BISHOP, COOK, PURCELL & REYNOLDS |
| References | |
| OL-2, NUDOCS 8408140495 | |
| Download: ML20094J898 (3) | |
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. =.. a;;m;g TRIAL LAWYERS FOR PUBUC juST1CE. P.C.
COUN$tLLOR5 ATLM SUITE 611 2000 P STREET. NORTHWEST MMSHINGTMj6.C' 20036 d
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'8 4(202) 463 8600AGO 14 A9:57 1984 3,U,ii,dAugust 13, 0GCY
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Leonard Belter, Esquire Bishop, Lieberman, Cook, Purcell & Reynolds 1200 17th Street, NW Washington, DC 20036 Re:
In the Matter o f TEXAS UTILITIES ELECTRIC COMPANY, et al. (Comanche Peak Steam Electric Station, Units 1 and 2 ) ; Docket No s.
50-445-2 and 50-446-2
Dear Len:
The purpose of this letter is to tie up the loose ends on requests for documents by CASE arising out of the depositions taken in Glen Ibse.
As you recall I gave you a handwritten note which was typed by your secretary which contained the requests as of the end of the second week.
As we complete the review of transcripts I will let you know if more items come up.
I now have a copy of that list and with one exception this letter relates to those items.
I have attached a copy of the list with numerous handwritten notations on it.
No one here knows what item 1 is and unless we have my original note I doubt that we can figure it out.
Item 2 relates to interviews which it was believed were conducted by Brown &
3 Roo t o ut o f Ho uston o f some the QC in spec tor s.
We still want the 4
interviews or a statement indicating what happened to them and a witness who can tell us about the interviews (why, when, o f whom, what learned, etc. ).
As to item 3 we do not have any written doc ument.
If there was one and you gave it to us, could we get i
another copy.
If there is no copy o f such a memo we want 'Ibison to indicate whether he wrote one or not.
This could be part of his rebuttal direct.
Items 4, 5, 7, 8, 10, and 11 are completed and the documents received by us or acknowledged by you to not exist.
Item 6 remains open and we are anxious to have the minutes, tr anscr ipts, tapes or anything else that records the meeting between plant personnel and O.
B. Cannon personnel, including Lipinsky sometime after the Lipinsky meno was written.
Item 9 relates to testinony by 'Ibison indicating that he did not complete his investigation of the charges that destructive testing was being done in the safeguards building by electrical QC but believes it was com-pleted by someone.
We want to see any written documents relevant B408140495 840813 PDR ADOCK 05000445
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T 2-to those charges including any finel report or we want testimony by someone with personal knowledge to tell us what happened to the investigation after 'Ibison changed jobs.
Items 12 and 13 relate to the steps being taken in connee-tion with the "8 Point Program. "
Item 12 is the agenda of the meeting with the lawyers on employment requirements.
If it does not exist we need a written statement to that affect.
Item 13 is the correspondence between the audiovisual consultant and TUGCO regarding the slide show.
If the scope of that consultation is narrower than assumed and no written documents exist we need a written statement to that effect.
Finally, one item not.on my list but that arose during the Neumeyer deposition and subsequent conference call with the Board is the documents relevant to the stainless steel liner incident.
We understand that the documents to be produced are (1) all pages of the travelers used by Mac in the deposition; and (2) all the remaining travelers for which Susie was asked to sign off based on the " chits. "
We need a written status report on this if we are not going to have the documents by the close of busines on Thursday, August 16.
If you have any questions please call me.
Thanks for your cooperation on these matters.
Sincere y, s
hony Z.
is an i
Exec utiv irec tor i
Enclo sure cc:
All the persons on the service list.
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].J THINGS DUE:
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Boyce Grier notesp supa n
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B&R interviews (from Hot.ston)
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Lipinsky mgt, transcript
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9 Follow-up investigation of destructive testing in Safeguards b1dg.
4 (Woott seespSou e ye w con...u,featien en ai..L C y.c3.a... 4 tters ha weerr-fino ai.J cair.p; :y dh K @(Belter) Cedf5 Q wps s
M/ trenk3 mW' 2c-h Kui-cri 6er4 dseviica t-Agenda of the meetjng uf MO M4
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Comm nic t ons with AV company L o# # $~0'
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Cali Bud.d on witness 6 discovery deposition and scope of future X-exam 2
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