ML20112C251

Confirms 850102 Telcon Re Intervenor Objections to Adequacy of Applicant 841228 Responses to Intervenor Second Set of Interrogatories & Request for Production of Documents. Related Correspondence

ML20112C251
Person / Time
Site:	Hope Creek
Issue date:	01/08/1985
From:	Thurber J NEW JERSEY, STATE OF
To:	Laverty J CONNER & WETTERHAHN
References
CON-#185-012, CON-#185-12 OL, NUDOCS 8501110103
Download: ML20112C251 (2)

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1. tate of Neus ilerseg DEPARTMENT OF THE PUBLIC ADVOCATE DIVISION OF PUBLIC INTEREST ADVOCACY G Dhs"[c CN 950 JOSEPH H. RODRIGUEZ TRENTON. NEW JERSEY 08425 RICetAm,3 E. $ HAP!40 PUBUC ADVOCATE DIRECTOR 0 g. ,ge m.a..un January 8, 1985 hk BR RE7m ERvict, Ms. Jessica H. Laverty Conner and Wetterhahn 1747 Pennsylvania Avenue, NW 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 confirms our telephone conversation of January 2, 1985, during which you and Richard'Fryling of PSE&G discussed with me the Intervenor's objections to the adequacy of Applicants' responses, dated December 28, 1984, to "Intervenor's Second Set of Interrogatories and Request for Production of Documents to Applicants." This letter identifies all of the agreements we reached regarding these responses.

With regard to Interrogatory I. 36, we agreed Applicants would supplement their response by providing the information re-quested by the third sentence of this interrogatory. W2 also agreed that Applicants would provide the information sought by the second sentence of this interrogatory after Intervenor supplements his answer to Applicants' interrogatories regarding the substance of his experts' testimony.

With regard to Intervenor's concern over the sufficiency and specificity of Applicants' response to Interrogatory III. 6, you stated that all of the suggestions made by the NRC were contained in the documents referenced by your response.

With regard to Interrogatory III. 7, you stated that Applicants were unwilling.to discuss any possible modification of the response to this' interrogatory due to yourposition that the information regarding Salem sought by the interrogatory was irrelevant to any of Intervenor's contentions.

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8601110103 850108 PDR ADOCK 05000354 0 PDR New Jeney is An Equal Opponunity Employer } Q}.

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- Ms. Jessica Laverty- January 8, 1985 With regard to Intervenor's concern that the Applicants' response to Interrogatory III:. 8 was unresponsive, you stated that all of the requested indormation was contained in the referenced documents.

Similarly, with regard to Intervenor's concern that the Applicants' response to Intecrogatory III 9 was incomplete,

- you stated that all of the requested documents had been identified in the referenced. response to Interrogatory III. 3.

With regard to Intervenor'.s concern that the Applicants' response to Interrogatory III. 11 was incomplete, you stated that all of the requested information was contained in the referenced documents.

With regard to Interrcigatory III.14, we agreed that Applicants would supplement their response by providing the information requested by the third sentence of the interrogatory,

, We also agreed that Applicants would provide the information sought by the second sentence of this interrogatory after Inter-

venor supplements his answer to Applicants' interrogatories

- regarding.the substance of his experts' testimony.

With regard to Interrogatory III. 47, we agreed that Applicants would supplement their responses by providing specific course inforn2 tion.

With regard to Interrogatory V. 10, we agreed that Appli-cants would provide the requested specific information.

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Finally, with regard to Interrogatory V. 22, we agreed that Applicants would supplement their response by providing the information requested by the third sentence of the inter-rogatory. We also agreed t. hat Applicants'would provide the

' information sought by the second sentence of this interrogatory l-after Intervenor supplements his answers to Applicants' inter-

- rogatories regarding the susbstance of his experts' testimony.

1.

Sincerely, 1-JOHN P. THURBER b

Assistant Deputy Public Advocate ,

JPT/ap

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