ML20207E039

Requests Search of Files for Info & Documents Supplementing Encl NRC 850808,860206 & 0602 Answers to Discovery Request, Per Board 860703 Order.W/O Encl.Related Correspondence

ML20207E039
Person / Time
Site:	Braidwood
Issue date:	07/14/1986
From:	Cunningham G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
CON-#386-020, CON-#386-20 OL, NUDOCS 8607220251
Download: ML20207E039 (1)

Text

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. OFFICE OF SEutt.lARY 00CMETING A SERVICE BRANCH Memorandum To: James G. Keppler Regional Administrator, Region III From: Guy H. Cunningham, III PRO D. & J F C. 7 I C!

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Deputy General Counsel

SUBJECT:

REQUEST FOR REGION III TO SEARCH ITS FILES d4 FOR DOCUMENTS RESPONSIVE TO LICENSING BOARD'S ORDER IN TIIE BRAIDWOOD PROCEEDING DIRECTING THE NRC STAFF TO UPDATE ITS ANSWERS TO DISCOVERY REQUEST .

This memorandum is to reouest assistance from Region III to respond to the Licensing Board's Order in the Braidwood proceeding for the Staff to update its answers to discovery requests.

During the July 3,1986 session of the ongoing hearing in the Braidwood operating license proceeding, the Licensing Board directed the NRC Staff to conduct a thorough search of its files and disclose any information or documents responsive to discovery previously addressed to the Staff.

The thrust of the past discovery requests by both Intervenors and Applicant was for disclosure of all details relating to complaints by L.K.

Comstock Quality Control inspectors or other Quality Assurance personnel regarding harassment and/or intimidation by Comstock QA/QC management or supervisors while working at the Braidwood site. The Staff provided answers to the Intervenors on August 8,1985 and February 6,1986 (see responses to Interrogatory 55) and to the Applicant on January 10, 1986.

Copies of these answers are provided to assist in Region III's search of its files.

In order to be responsive to the Board's direction, the search should include both the official Region III files as well as individual Staff member's files (including those of current and past resident inspectors) for responsive documents and information not provided in the three enclosures. All information and documents should be disclosed to Staff counsel, including records of receipt of allegations, inspection reports, i

drafts of inspection reports, any personal notes of Staff members in their files, any notes or minutes of interviews of meetings, etc. Any document for which confidentiality or privilege is aserted should be identified and produced for Staff counsel and the basis for asserting privilege or confidentiality set forth.

Thank you for your assistance and that of your staff in this atter.

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Nf o

51 860714 CK 05000456 Guy H. Cunn

/ ', 4-DR Deputy General Counsel

Enclosures:

As stated hs67

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