ML20128K139
| ML20128K139 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/06/1985 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Wooldridge R WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| References | |
| CON-#385-749 OL, NUDOCS 8507100490 | |
| Download: ML20128K139 (2) | |
Text
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RELATED CORRESPONDENCE C A S E==
(CITIZENS ASSN. FOR SOUND ENERGY)
July 6, 1985 DCCMTED Robert A. Wooldridge, Esq.
Worsham, Forsythe, Sampels & Wooldridge 2500 - 2001 Bryan Tower
'85 JUL -9 A10 32 Dallas, Texas 75201
Dear Bob:
CfflLE F S W tile 00CXmf'G a SE6 vira BRANCH
Subject:
In the lhtter of Texas Utilities Electric Company, et al.
Request for an Operating License for Comanche Peak Steam Electric Station, Units I and 2 Docket Nos. 50-445 and 50-4460L-Discovery Requests In Mr. Roisman's 5/28/85 letter to you regarding informal discovery requests, he stated, in part (page six):
"To the extent any request is deemed by you to be outside the ccope of Docket 2 we are authorized by Ms. Ellis to state that the request should be considered a Docket I request.
Since this is an informal request, as suggested by Judge Bloch, there is no time limit but we would appreciate a written indication from you within the next week regarding your willingness to participate in this informal discovery and your anticipated schedule for response."
There are a couple of aspects of this to which we would like to call your attention.
First, CASE in the main docket considers all the questions set forth in Mr. Roisman's letter to be questions to which we would also like Please be sure that we are also provided with copies of all answers.
responses you supply in Docket -2.
Also, the term " documents" should be construed as set forth in item 3, page 2, of CASE's 6/24/85 Interrogatories to Applicants and Requests to Produce re: the MAC Report and Issues Raised by the MAC Report.
We have not seen any response from you to Mr. Roisman's request that you provide a written indication regarding your willingness to participate in this informal discovery or your anticipated schedule for response. We note that several of these requests pertain specifically to the qualifications of officials and consultants, regarding which the Board ordered that
" Applicants shall respond in a prompt fashion to outstanding discovery requests concerning qualifications of officials and consultants" (see Board's 5/24/85 Memorandum and Order (Case Management Plan),, page 5, item 3).
We have not yet thoroughly reviewed Applicants' recent filing of the CPRT plan; however, it appears from a very cursory review of it that some of the requested information is not contained therein.
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,g CASE considers the information requested to be an absolutely essential ingredient for us to be able to adequately respond to Applicants' 6/28/85 Current Management Views and Management Plan for Resolution of All Issues and its attachment, the CPRT Plan (which CASE in the main docket did not receive until 3:25 P.M. on 7/3/85). To the extent that the requested information is not included in Applicants'. filings, please advise when we may expect such responses (as well as the others included in Mr. Roisman's filing).
Sincerely, 22 A+ Ou fALM JMrs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 cc:
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