ML20101M527

Clarifies Understanding Reached During 841218 & 19 Telcons Re Applicant Objections to Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents to Applicant.Related Correspondence

ML20101M527
Person / Time
Site:	Hope Creek
Issue date:	12/28/1984
From:	Shapiro R NEW JERSEY, STATE OF
To:	Laverty J CONNER & WETTERHAHN
References
CON-#185-887 OL, NUDOCS 8501030136
Download: ML20101M527 (2)

Text

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i State of Netu Berseg fiME' DEPARTMENT OF THE PUBLIC ADVOCATE j DIVISION OF PUBLIC INTEREST ADVQgACY. . ..

en ese ' 't i .3 JOSEPH M. RODRIGUEZ TRENTON, NEW JER$EY Oett$ P134 RICHARD E. SHAPIRO DUBLIC ADVOCATE  ; . DIRECTOR

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TEL: 609-292 1693 3 d f", b 1.,

December 28, 1984 Ms. Jessica H. Laverty Conner & Wetterhahn 1747 Pennsylvania Avenue, N.W.

Washington, DC 20006 ,

Re: In The Matter of Public Service Electric and Gas Company (Hope Creek. Generating. Station)

Docket No. 50-354 OL ,

Dear Ms. Laverty:

This letter is to clarify our understanding of the telephone conversations of December 18 and 19,1984,- during which you and Richard Fryling of PSE&G discussed with John Thurber and me the Applicants' objections to "Intervenor's Second Set of Interrogatories and Request for Production of Documents to Appli-cants," dated December 13, 1984. This letter sets forth each instance in which the agreements we reached are not fully or accurately reflected in your confirmatory letter of December 20, 1984.

With regard to the second paragraph of the first page of your letter, we do not recall agreeing to the scope of Conten-tion One. Our agreement was limited to the specific wording of several interrogatories and document requests in Sections I and II, as you indicated in the second sentence of that paragraph. We did not intend by these discussions to express any opinion as to

, the scope of contention One.

With regard to Interrogatory 1. 30, we further agreed that af ter the Public Advocate has evaluated the Applicants' answer

'; to the first sentence of this interrogatory, he will have the oppor-tunity to follow-up with further interrogatories on that issue.

>. With regard to Interrogatories I. 33 and I 34, your letter differs from our understanding of the agreement we reached on December 19, 1984. Our notes indicate that Richard Fryling had proposed the following response to this interrogatory to which both we and you had agreed:

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Ms. Jessica H. Laverty December 28,' 1984

" Irrelevant. Applicants will not raise I:'

economic infeasibility in this proceeding."

Similarly, we agreed that in response to Request II. 7, you would respond: "See answer to interrogatory I. 33 and I. 34."

With regard to Interrogatory III. 30, we agreed to rewrite the interrogatory as follows:

" Describe all steps taken to ' integrate more fully the nuclear engineering organi-zation into plant operations' at Hope Creek '

as recommended bE. BETA with respect to the l Salem Generating Station at page 18 of its May, 21, 1983 recort."

With regard to Request IV. 19, we agreed that the Public Advocate would withdraw this document requ6st.pending our review of the documents in the possession of the Rate Counsel.

With regard to Request IV. 25, you' stated on both December 18 and 19 that Applicants were not willing to discuss any possible modifications of this request due to your position that all of the documents requested by Intervenor were privileged.

Finally, with regard to . Interrogatory v.10, we further agreed to delete the words "at any plant."

I hope that this letter clarifies the Intervenor's understanding of the nature and scope of our agreements relating

to the second set of interrogatories and requ6sts for production of documents.

Sincerely, fala E. d4~/+

Richard E. Shapiro Director RES/ap cc: Service List

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