ML20206P951

From kanterella
Jump to navigation Jump to search
Forwards List of Questions from Case Credibility Discovery Requests Which Applicant Considers Outside Scope of Inquiry. Applicant Response to Remaining Questions Will Be Provided by 860630.Related Correspondence
ML20206P951
Person / Time
Site: Comanche Peak  Luminant icon.png
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

.f h WMD CORRESPONDENCL ii 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 stSHOP, LIBERM AN & COOK TELtx e40574 4NTLAW (J e TELecopica (2o2p es7-seas <<ss avcNuc or Tuc AucascAs 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 to the remaini been provided.gg requests as to which answers have not already l

Sincerely [

l

%)

WillIamA. Horin I Counsel for Applicants

/ Overnight Delivery cc: Service List (First Class Mail) l L

1/ Applicants previously filed replies to CASE's " credibility" requests in responses dated March 13, April 25, June 28, July 1, July 3 and July 5, 1985, and March 31, 1986.

i 8607020306 860623 PDR ADOCK 05000445 l

Dsok

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, miscellaneous questions not related to Applicants' Plan)

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 l

None.

l l

l/

To assist CASE in understanding Applicants' position regarding each of the above question's relevance to Applicants' Plan, the general subject matter of each request is summarized. Those brief descriptions are not 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.

, _ -- . . _ . _ _ . . - _ . _ _ _