ML20137A841

Memorializes Agreements Re Production of Business & Prof People for Public Interest Documents Concerning Intervenor Second Set of QA Interrogatories & Requests to Produce. Related Correspondence

ML20137A841
Person / Time
Site:	Braidwood
Issue date:	01/10/1986
From:	Babb S ISHAM, LINCOLN & BEALE
To:	Guild R BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES
References
CON-#186-727 OL, NUDOCS 8601140558
Download: ML20137A841 (3)

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i'p' ISHAM, UNCOLNTBEALE COUNSELOR $ AT LAW C0thEIL:

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January 10, 1986 [

BY MESSENGER l

Robert Guild, Esq. .

Business and Professional People }

for the Public Interest 5 109 North

Dearborn,

Suite 1300 Chicago, Illinois 60602 {

t RE: In re Commonwealth Edison Company (Braidwood Station, Units 1 and 2), NRC Docket Nos. f 50-456, 50-457 Q C

Dear Bob:

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' This letter memorializes ~our agreements concerning i production of BCAP documents pursuant to Intervenor's Second  !

Set of QA Interrogatories and Requests to Produce ("Second l Set"). In Applicant's Third Partial Response to the Second  !

Set, filed December 6, 1985, Applicant offered to make the  !

massive volume of BCAP documentation created or maintained by the ~BCAP. Task Force, ECAP QA, and Sargent & Lundy available for Intervenors' inspection and copying at the locations '

where the document.s were stored. Applicant also provided [

over 100 pages of indices describing the documents and their r filing systems. On December 13, 1985, Applicant's Fourth Partial Response supplemented these indices.

In a December 11, 1985 phone conversation,.you  !

expressed your interest in viewing the documents on the t Braidwood site. At this time, I' told you that the documents '

Lf would be available for Intervenors' review at the site any  !

work day after December'19, 1985 provided you could give me j one week's notice prior to the date on which you wished to

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review the on-site documents. You indicated that you and  ;

your colleagues would not be available.to review these  :

documents until the week after Christmas or the first week t

of January,1986. We discussed the indices and you mentioned  !

that there were a number of things you knew you~ wanted to

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8601140558 960110 PDR ADOCM 05000456

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copy, but at that tine you could not specifically designate  :

the items. You also requested an organizational chart l listing names-and positions of BCAP personnel. (An historic j listing of BCAP personnel and their titles was provided in ,

Applicant's Fourth Partial Response on December 13, 1985). i On December 13, 1985, we again discussed pro-duction of BCAP documents. At that time I indicated that if 1 1

you would send copies of the indices with your requests marked on them, I would evaluate the volume of your requests and the feasibility of Applicant making copies of these documents for your review in Chicago. I also indicated that for document control reasons we would want to Bates stamp all documents brought to Chicago. At this time you indicated t

your reluctance to review documents on Braidwood. A copy of L your marked up indices was delivered to our office on

. December 13, 1986 after I had left the office for the day.

Today, we came to the following agreements con-

, cerning production of BCAP documents. First, you requested documents located on site in the QA vault. As this request represents a manageable volume of documents, all these i documents will be copied, Bates stamped and.made available-for your review at Isham, Lincoln & Beale by Friday, January 17, 1986. These documents consist of all documents except a as noted on package indices you selected from Attachment 5 of Applicant's Third Partial Response (documents filed under QG 69.30.4 through QG 69.30.7 for the following populations G-ASM, G-CEA, G-ELE, S-001, E-CBL, H-06, H-10 M-002, M-004, and M-012) and documents filed under the following file numbers as indicated on your marked up Attachment 1: QG-a 69.10.4, 69.10.7.6, 69.10.7.10, 69.10.7.13, 69.10.7.14, ,

69.20.18, 69.30.9, 69.40.7, and 69.81.1 through 69.81.5. In addition, per your modifications, copies of the following i documents will also be available at Isham, Lincol & Beale: i

, documents, if any, filed under file numbars QG 69.30.2, ,

69.40.2, 69.50.1.2, 69.60.1.3, 69.60.2.3, 69.62.5, and l j 69.70.2 (see' Attachment 1 to Applicant's Third Partial '

j Response); documents indicated on Attachment 4 of Applicant's 1

Third Partial Response by'the numbers 4, 7,J23, 24, 25, 28, j- 43, and 79; and documents filed under QG 69.30.4 through i 69.30.7 which were not transferred to the vault for the same populations indicated above-(these documents consist of -

j twelve files from the list under number 326 on Attachment 1 to Applicant's Fourth Partial Response) . Copies of these documents are being provided for your convenience and l Applicant makes no admission as to the relevancy of these I documents to the Amended-QA Contention.

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, 'Documents.from Attachment 4 for which you requested an estimate consist of: a) 63 binders of approximately 400 4

pages each and b) four banker's boxes of documents. This volume of documents and the ten file drawers of correspondence which you requested (QG 69.60.1.6 and 69.60.2.6) represent an unreasonable volume of documents to copy and transfer to Chicago.

All BCAP documents listed on Attachment 1 of

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Applicant's Third Partial Response which are not located in the QA Vault and all documents listed on the Index Listing of BCAP Informal Files (Attachment 4 of Applicant's Third Partial Response and Attachment of Applicant.'s Fourth

. Partial Response) will be available for your review at the Braidwood site on Thursday, January 16,.1986, per your d

request. No arrangements have been made for your review at that time of either documents stored in the QA vault or Sargent & Lundy documents located on site.

Applicant has expended significant effort to organize these documents and store them in a manner that j will allow Intervenor's review. If you should choose not to 1

review BCAP documents on site, Applicant will copy additional i documents which you may request without your prior review at an expense of ten cents ($.10) a page to BPI.

i Please let me know if this letter does not reflect

our agreements today for production of BCAP documents. With regard to your January 16 visit to the site, I need to know when you anticipate arriving at the Braidwood site. If you l- wish, transportation to the site with an IL&B attorney can be arranged.

Sincerely, Susan E. Babb SEB:jk l cc: Attached Service List e

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