ML20107A101
| ML20107A101 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/14/1985 |
| From: | Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-596 OL, NUDOCS 8502190284 | |
| Download: ML20107A101 (4) | |
Text
A.
WTED CORRESPONDENCE February 14, 1985 7 4 f "([
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'~en UNITED STATES OF AMERICA
, h/
t NUCLEAR REGULATORY COMMISSION U'
BEFORE iHF ATOMIC SAFETY AND LICENSING B R
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In the Matter of
)
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)
Docket Nos. 50-445 and TEXAS' UTILITIES ELECTRIC
)
)
)
(Application fo q _
(Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
)
APPLICANTS' MOTION FOR PROTECTIVE ORDER REGARDING CASE'S SECOND SET OF INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE RE:
CREDIBILITY Pursuant to 10 C.F.R.
$2.740(c), Texas Utilities Electric
-Company, et al.'(" Applicants") hereby move for a protective order
_with respect to " CASE's Second Set of Interrogatories to Appli-cants and Requests to Produce Re: Credibility," dated February 4, 1985.
CASE premises its' discovery requests on the Board's reopening of discovery in its December 18, 1984, Memorandum (Reopening ~ Discovery; Misleading Statement).
Applicants request that the time for. responding to CASE's discovery requests not begin to run until the Board has ruled on Applicants' motion fo r reconsideration of the Board's Memoran6am.
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A Applicants previously filed, on January 23, 1985, a motion
.for protective: order with respect to CASE's first set of inter-rogatories "re: credibility."
Applicants' position regarding the
' need.for. a protective order covering CASE's discovery requests is
- set forth in that motion, and we adopt herein those arguments.
Further, we note that as with the first set, the second set "of discovery requests, which principally seeks information regarding certain industry standards and communications between zApplicants:and Cygna and Applicants and Professor Boresi, concern matters not within the scope of discovery that Applicants voluntarily agreed to in their motion for reconsideration, viz.,
the sampling performed in connection with' Applicants' motions for summary disposition submitted pursuant to Applicants' Plan.
^ Consequently, if the Board grants Applicants' motion for recon-
. sideration, Applicants would not be required to answer the subject requests.
Accordingly, a protective order suspending the running of time'for responding to CASE's-requests is appropriate.
Respec fu y submitted, t
i Ii
/
As Nichoy $ S.')Reynolds Willia A. IHorin BISHOP, LI RMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9817 Counsel for Applicants February 14, 1985
r M
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC
)
)
)
( Application for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion for Protective Order Regarding CASE's Second Set of Interrogatories to Applicants and Requests to Produce Re: Credibility", in the above-captioned matter was served upon the following persons by express mail (*) or deposit in the United States mail, first class, postage prepaid, this 14th day of February, 1985, or by hand delivery (**) on the 15th day of February, 1985.
- Peter B.
Bloch, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. William L.
Clements
- Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S.
Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.
20555
- Dr. Kenneth A.
McCollom Dean, Division of Engineering
- Stuart A. Treby, Esq.
. Architecture and Technology Office of the Executive Oklahoma Stat,e University Legal Director Stillwater, txlahoma 74074 U.S.
Nuclear Regulatory Commission Chairman, Atomic-Safety 7735 Old Georgetown Road and Licensing Board Panel Room 10117 U.S.
Nuclear Regulatory Bethesda, Maryland 20814 Commission Washington, D.C.
20555
_f
i,
%' Robert D.
Martin Elizabeth B. Johnson Regional Administrator, Oak Ridge National Laboratory Region IV Post Office Box X U.S. Nuclear Regulatory Building 3500 Commission-Oak Ridge, Tennessee 37830 611 Ryan Plaza Drive Suite 1000 "rs. Juanita Ellis
-Arlington, Texas 76011 President, CASE 1426 South Polk Street Renea Hicks, Esq.
Dallas, Texas 75224 Assistant Attorney General Environmental Protection Lanny A.
Sinkin Division Executive Director P.O.
Box 12548 Nuclear Information and Capitol Station Resource Service Austin, Texas 78711 1346 Connecticut Avenue, N.W.
4th Floor Washington, D.C.
20036 L
William A. Horin ~ ~
cc:
John W.
Beck Robert Wooldridge, Esq.
- -