ML20127K580

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Discusses Status of Discovery Requests in Facility Proceeding.Applicant Expected to Provide Responses to Interrogatories & Requests to Produce Documents Re Credibility by 850625.Related Correspondence
ML20127K580
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/24/1985
From: Ellis J
Citizens Association for Sound Energy
To: Wooldridge R
WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
References
CON-#285-586 OL, NUDOCS 8506270497
Download: ML20127K580 (2)


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REl.ATED CORRfLPONDQC$

C A S E (CITIZENS ASSN. FOR SOUND ENERGY) 1426 S. Polk Dallag, g s y 224 PROD.

214/946-94NTIL FAC..

,k-Mkdb ygED June 24, 1985 Robert A. Wooldridge, Esq. '85 JUN 26 Pl2:00 Worsham, Forsythe, Sampels & Wooldridge 2500 - 2001 Bryan Tower GFFICE OF SECiE: s-Dallas, Texas -75201 00CXETING A SERvid BRANCH

Dear Bob:

Subject:

In the Matter of Texas Utilities Electric Company, et al.

Comanche Peak Steam Electric Station Units 1 and 2 Discovery Requests I tried to telephone you Friday (6/21/85), but you were in a meeting, so I left word asking you to call. (I had been sick in bed from Saturday, 6/15/85, till Thursday, 6/20/85, and Friday was the first day I felt up to calling.) There are a fev discovery matters I want to call to your attention:

1. I spoke to Bill Horin Friday (6/21/85) regarding our most immediate concern: whether or not we could expect some responses to our interrogatories and requests to produce (re: Credibility) on Friday (6/21/85), as agreed upon. He said that Applicants would not be able to get anything out Friday, but that some answers and/or documents would be put in the mail on Monday (today) and that I should receive them on Tuesday (tomorrow). We trust that you will be able to meet the agreed-upon schedule of delivery by Friday of each week in the future.

If there is some problem with this, we would appreciate you or Bill.

Horin advising us in advance so that we do not have to spend CASE's money unnecessarily by having to telephone Washington (as I did Friday).

2. As part of our agreement regarding discovery -(re: Credibility), I agreed to let you know in advance if there were problems so we could discuss them prior to our going to the Licensing Board. Please ,

consider this to be such notification. We do not consider Applicants'

, 6/7/85 Report Regarding Status of Replies to CASE Interrogatories to be entirely consistent with our agreement. If you'd like to discuss this further, please call me to set up a time.

In addition, it is obvious from a review of Applicants' responses received to date that it will be necessary at some point in time to file a Motion to Compel. However, we will await receipt of whatever additional responses Applicants are going to provide between now and July 5 (the agreed-upon end date by which Applicants are to have responded to all our requests re: Credibility).

/D h 8506270497 850624 ADOCK 05000445

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3. At the end of the 6/14/85 NRC Staff / Applicants meeting, I raised certain questions which occurred to me off the top of my head as I listened to Applicants' presentations. (It was at the end of the meeting; John Beck stated that he expected to have a copy of the transcript by Monday, 6/17/85, so I assume you have it by now and can identify the transcript page numbers.) We assume that some of these matters will be covered in the filing which Applicants have committed to the Staff to make on 6/28/85. However, to the extent which they are not covered in that filing, please consider them to be informal discovery requests which we will then formalize if necessary. In addition, I expect that we will have additional discovery requests after we have a chance to review the transcript of the June 13 and 14 meetings.

We hope that we will be able to werk informally with you on these matters.

However, in all candor, our past experiences in this regard have not been very successful. But we are still willing to try, as long as it appears productive.

Sincerely, CASE (Citizens Association for Sound Energy) rs.) Juanita Ellis President cc: Service List 2