ML20133B905
| ML20133B905 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/01/1985 |
| From: | Guild R GUILD, R., ROREM, B. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| CON-#385-095, CON-#385-95 OL, NUDOCS 8508060286 | |
| Download: ML20133B905 (43) | |
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gg.ATED 00RRESM August 1, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DCLKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'In the Matter of:
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50-4560L [0ck N $ I$~
F COMMONWEALTH EDISON COMPANY
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Docket Nos.
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50-457 BRANCH (Braidwood Nuclear Power
)
Station, Units 1 and 2)
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RESPONSE TO NRC STAFF INTERROGATORIES TO INTERVENOR BRIDGET LITTLE ROREM, ET AL.
CONCERNING ITS QUALITY ASSURANCE CONTENTION AND MOTION FOR PROTECTIVE ORDER Intervenors Bridget Little Rorem, et al., by their under-signed counsel, hereby respond to NRC Staff Interrogatories to Intervenor Bridget Little Rorem, et al. concerning their Quality Assurance Contention, which were served July 12,* 1985.
Pursuant to 10 CFR Section 2.740(c), Intervenors move for the
. entry of a protective order as to each interrogatory and request for production of documents, or portion thereof, as to which they herein object.
-By way of introduction Intervenors note that their discovery requests of Applicant and the NRC Staff, consisting of interrogatories and requests to produce documents served July 2, 1985, remain substantially unanswered.
Obj ections by the Applicant and the NRC Staff interposed against the majority of our interrogatories were served July 29, and July 30, 1985, respectively.
As directed by the Board Intervenors intend to 8500060286 850003 f.ADOCK 05000456 PDR mob u
seek voluntary agreement by Applicant 'and the NRC Staff to supply'further responses to interrogatories presently the subject of their objections and, as necessary, to seek an order pursuant to 10 CFR Section 2.740(f) compelling such discovery absent agreement.
. Applicant has served partial answers to only nine (9) of Intervenors ' sixty-two (62) interrogatories, together with
.related documents and listings of documents to be made available for ' inspection.
This "first increment" response was delivered to Intervenors' counsel after close of business July 30, 1985.
At this time Intervenors have not had sufficient opportunity to examine, inspect and evaluate the information in order to incorporate miy such information in this response.
Under the schedule approved by the Board at the July 23, 1985, Prehearing Conference complete answers to Intervenors' -interrogatories and requests for production are to be served August 9, 1985.
The NRC Staff's responses are expected shortly.
In submitting their proposed quality assurance contention Intervenors were required by the Licensing Board to provide "a precise specification of each occurrence of an alleged QA/QC deficiency," and "the data on which each alleged deficiency is premised (e.g., NRC inspection reports)," as the bases for our amended contention.
Special Prehearing Conference Order, April'17, 1985, at p. 41.
That is what Intervenors have done.
Thus, to the extent that.the NRC Staff interrogatories seek identification of the l,
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