ML20127P800

Forwards Discovery Requests Under ASLB 841218 Memorandum (Reopening Discovery,Misleading Statement)

ML20127P800
Person / Time
Site:	Comanche Peak
Issue date:	05/20/1985
From:	Ellis J Citizens Association for Sound Energy
To:	Treby S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#285-123 OL, OL-2, NUDOCS 8505240085
Download: ML20127P800 (2)

Text

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C A S E (CITIZENS ASSN. FOR SOUND ENERGY)

== ___. 1 May 20, 1985 T

Mr. Stuart Treby 3fgC Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555

'85 HM 23 All:07

Subject:

In the Matter of -

TexasUtilitiesElectricCompany,hfh 3 Comanche Peak Steam Electric Station, BRANCH Units 1 and 2 Docket Nos. 50-445 and 50-446 O L.

Discovery Under Board's 12/18/84 Memorandum (Reopening Discovery; Misleading Statement)

Dear Stuart:

As we discussed in the off-the-record telephone conference call on 5/7/85 and in CASE's 5/13/85 Answer to Applicants' 4/26/85 Proposed Case Mar.agement Plan (in Main Docket, 50-445 and 50-446) (page 4, Footnote 3), we have reviewed CASE's First through Fourth Set of Interrogatories to Applicants and Requests to Produce Re: Credibility.

It is our understanding that the Staff has asked questions and requested documents from Applicants informally (but not in writing). Therefore, much of the information which CASE has requested will simply put CASE on a more even footing with the Staff and allow us to also receive the same or similar information as the Staff has already had access to and reviewed. In other instances, the information sought is of the type which we do not believe the Staff would be pursuing.

On the attached sheet, we have listed questions and requests for documents which we believe the Staff probably is not reviewing at this time (where there is some question, we have indicated by a qu'estion mark or comment in parentheses). If the Staff is pursuing any of the information indicated on the attached sheet, please indicate the status of each such question (we ,

assume that most in this category would be something like "information requested; awaiting response by Applicants").

Thanks for your assistance.

Sincerely, E

g ?rs.) Juanita Ellis, President cc: Service List 8505240085 850520 PDR O ADOCK 05000445 PDR

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t Discovery Requests by CAS2 Under Board's 12/18/84 Memorandum (Reopening Discovery; Misleading Statement):

CASE's 1/17/85 First Set (entire Set):

1 and 2 CASE's 2/4/85 Second Set (entire Set):

I through 5 CASE's 2/25/85 Third Set (entire Set): -

1 through 58 CASE's 2/25/85 Fourth Set:

1 through 9 7 (Questions 1 through 9 have to do with design / design OA issues which the Staff may be reviewing regarding summary disposition or Cygna issues; however, if the Staff has already reviewed or received the information requested, CASE should now be supplied with the same information. CASE believes that only if the Staff has requested such information, but Applicants have not yet supplied it, would the information come under the Board's ruling that Applicants do not have to supply the information at this time; in that case, according to our agreement with Mr. Wooldridge, we would receive a copy of the information at the same time as the Staff.)

10 through 42 2