ML20207Q272

M Gregory Request for Production of Documents (Set 6).* Certificate of Svc Encl.Related Correspondence

ML20207Q272
Person / Time
Site:	Comanche Peak
Issue date:	01/16/1987
From:	Roisman A GREGORY, M., TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
CON-#187-2239 CPA, NUDOCS 8701270109
Download: ML20207Q272 (6)

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• F 2239 """ Wt'P"'N BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Of[hc Before the Atomic Safety and Licensing Board

'87 JM4 20 P4 :18 In the Matter of ) 0FF;CE ur ic OCC!E M ' ev:

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TEXAS UTILITIES GENERATING COMPANY, ) Dkt. Nos. 50-445-CPA et al. )

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(Comanche Peak Steam Electric )

Station, Unit 1) )

MEDDIE GREGORY'S REQUEST FOR PRODUCTION OF DOCUMENTS (Set 6)

Please respond to the following requests for production of documents within the time limits specified by the NRC regulations and pursuant to the requirements of those regulations.

For purposes of this document, the following definitions and guidelines for clarifying answers are applicable:

a. " Applicants" refers to each owner of CPSES and to each contractor, subcontractor, and consultant (including persons working for or with the CPRT). Each response should indicate that the document (s) provided represents the information in the possession of each and overy owner and that inquiry has been made to each contractor, subcontractor, and consultant, including those no longer employed at the site, and the responses received from them, if any. In addition, when documents are obtained from an owner other than TUEC or from any contractor, subcontractor, or consultant, 8701270109 870116

{DR ADOCK 05000445 PDR )hgh

the specific documents so obtained should be identified by, source whenever reasonably possible (i.e., from whom did TUEC obtain the document in order to answer the request?).

b. " Documents" refers to everything written or recorded in 4

any way, including draf ts and otherwise identical copies of the same docunents that contain substantive additions or deletions.

c. All requests should be regarded as separable and objections to portions of requests do 'not relieve Applicants of the duty to answer the remainder of the requests,

d. Where objections are interposed but documents provided, please indicat e to what extent the answer is a complete response and to what extent additional documents are being withheld because of the objection.

The foregoing definitions and guidelines are incorporated by reference into and are a par t of each of the following requests.

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Request for Production of Documents

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(Answers due in 30 days.)

The following requests arise from a statement contained in a pleading filed in Docket Nos. 50-445A and 50-446A entitled " Views of Brazos Electric Power Cooperative, Inc., Respecting Significant Changes Related To Antitrust Matters" (1/13/87) and appearing on page 5:

At present, TUEC is withholding from Brazos and the other CPSES owners the f ruits of a purportedly extensive investigation into TUEC's management of the project conducted by the firm of Cresap, McCormick & Paget . . . .

1. Produce a copy of all documents provided to Applicants by Cresap, McCormick & Paget (or any of their employees, contractors, or consultants) related to any investigation into TUEC's management of CPSES, including but not limited to the following : contracting documents; draft, preliminary, and final assessments, analyses, or conclusions; handwritten notes; notes written on other documents.

2. Produce a copy of all documents generated by Applicants ,

in response to any of the documents to which Request 1 relates, including but not limited to all notes, internal memoranda, notes I

written on copies of these or other documents, and written  !

communications with Cresap, McCormick & Paget or any of their j employees, contractors, or subcontractors.

3. Produce a copy of all documents prepared for, during, or as a result of any meetings between any employee (s), contractors, or consultants of Applicants and any employee (s), contractors, or consultants of Cresap, McCormick & Paget related to the

investigation being conducted by Cresap, McCormick & Paget.-

4. Produce-a copy of all documents generated by Cresap, McCormick & Paget or any of its employees, contractors, or consultants in the course of conducting their investigation.

Respectfully submitted,

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' ANTHONY Z. ROI '/

Trial Lawyers f r Public Justice 2000 P Stre , NW, #611 Washington, D.C. 20036 (202) 463-8600 Counsel for Meddie Gregory Dated: January 16, 1987 4

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UNITED STATES 00L KU,IQ NUCLEAR REGULATORY COMMISSION U9 ~

Before the Atomic Safety and Licensing agards Di V*

20 p418 In'the Matter of )

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TEXAS UTILITIES GENERATING COMPANY, ) Dkt. gpg,(,P*#[45 5006C Nos. 50-

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CPA et al. )

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(Comanche Peak Steam Electric )

Station, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of MEDDIE GREGORY'S REQUEST FOR PRODUCTION OF DOCUMENTS (Se t 6) were served today, January 16, 1987, by first class mail, or by hand where indicated by an asterisk, and by Federal Express where indicated by two asterisks, upon the following:

Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan Carib Terrace 552 North Ocean Blvd.

Pompano Beach, FL 33062 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, OK 74075 Elizabeth B. Johnson Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, TN 37d30 Nicholas Reynolds, Esq.

Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, NW Washington, D.C. 20036 L_

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' it Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l*

Geary S. Mizuno, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road, 10th floor Washington, D.C. 20555 Thomas G. Dignan, Jr. ',

Ropes & Gray

, 225 Franklin Street Boston, MA 02110

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e C/' ANTHONY Z. R SMA j i

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