ML20206P951
| ML20206P951 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/23/1986 |
| From: | Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Ellis J Citizens Association for Sound Energy |
| References | |
| CON-#386-784 OL, NUDOCS 8607020306 | |
| Download: ML20206P951 (2) | |
Text
O h
WMD CORRESPONDENCL
.f i i LAW OFFICES O F BISHOP, LIBERMAN, COOK PURCELL & REYNOLDS (200 S EVE NTE E NTH STR EET, N. W.
WAS HINGTON, D. C. 2 003 6 (2O2) 857-9800 DOCKETED in ucw vo M TELtx e40574 4NTLAW (J e stSHOP, LIBERM AN & COOK
<<ss avcNuc or Tuc AucascAs TELecopica (2o2p es7-seas June 25 WSO NO:45 (212) 704-o100 TELEX 222767 0FFICE OF Sf.UitTARY 00CMETING & SERVICf.
Mrs. Juanita Ellis
""',',',"[*"'""*^'
President, CASE g
1426 South Polk Street Dallas, Texas, 75224 Subj:
Texas Utilities Electric Company, et al.
(Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 40-446 0 L
Dear Juanita:
Attached is a list of questions from CASE's five sets of
" credibility" discovery requests which Applicants consider outside the scope of inquiry authorized by the Board, i.e.,
requests not "related to [ Applicants'] first Plan and its filings under that Plan" (Memorandum and Order (Reconsideration of Misrepresentation Memorandum), LBP-85-47, November 25, 1985, at 11).
I am providing this list to CASE in accordance with our agreement regarding responses to the credibility requests, memorialized in my June 12, 1986, letter to the Board.
- Also, pursuant to that agreement, Applicants will respond by June 30 been provided.gg requests as to which answers have not already to the remaini l
Sincerely [
%)
l WillIamA. Horin I
Counsel for Applicants
!/
Overnight Delivery cc:
Service List (First Class Mail) l L
Applicants previously filed replies to CASE's " credibility" 1/
requests in responses dated March 13, April 25, June 28, 31, 1986.
July 1, July 3 and July 5, 1985, and March i
8607020306 860623 PDR ADOCK 05000445 Dsok l
CASE's Credibility Requests y
outside Scope of Authorized Discovery First Set i
Questions 1(liberplate) and 2 (protective coatings)
Second Set Question 5 (damage studies)
Third set All questions (document control, Hatley allegations, Plan) miscellaneous questions not related to Applicants' Fourth Set Questions 9 (cable tray supports), 10-23 (witness preparation, welding, drug use), 24 (supports not related to Plan), 25 (partial; nonconforming conditions), 26-27 (pencil grinders), 28 (NCRs), 29-30 (ANI's, ASME survey), 31 (fuel load status), 37 (supplement discovery), 39 (protective coatings),
40-41 (additional discovery), and 42 (basis for responses to Board questions (pre-Plan issues)).
Fifth Set None.
l l
l To assist CASE in understanding Applicants' position l/
regarding each of the above question's relevance to Applicants' Plan, the general subject matter of each Those brief descriptions are not request is summarized.
intended, however, to serve as a complete objection to each question.
Also, if Applicants already answered questions which do not relate to Applicants' Plan, those questions are not included here.
_