ML20214W010

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Documents Understanding That NRC Will Respond to 860922 Discovery Request,To Provide Ofc of Investigations Rept Re Qa/Qc,By 861205.Related Correspondence
ML20214W010
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/04/1986
From: Roisman A
TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To: Chandler L
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#486-1795 CPA, OL, NUDOCS 8612100045
Download: ML20214W010 (2)


Text

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couNstuoRs ATiAw ., g SUITE 6tl MN"E 4000 P STREET. NORTHWEST 5" MHINGM DC 26

^"n'"Ed"?tCJ i '86 DEC -8 Pl2:28 (2 23 m e ARTHUR BRYANT situt cARot 6Ffict .~ . , , ' '

DIRECTOR. (NVIRoNMENTAL

  • wHrsiu8towtR rRolict 00CnF is i. It A NCw' #'il f. f SARBARA PRATT ornCtMANAGER December 4, 1986 KATHtitN CUMBER 8ATCH SECRETARY Larry Chandler BY HAND Office of Executive Legal Director U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road, 9th floor Bethesda, MD 20814 RE: ENCLOSED

Dear Larry:

The enclosed letter to Victor Stello requests production of the recent OIA report regarding QA/QC at Comanche Peak and Region'IV's involvement. We contend that this report is also.

covered by our previously filed discovery on CPRT adequacy (9/22/86), including but not limited to questions 2, 9, 13, 14, 19, and 35. According to the extension agreement you reached with my co-counsel Ms. Garde, it is my understanding that you will be providing your answers to this discovery tomorrow.

Sincerely, Anthony Z Roisman AZR/bp l

enclosure cc: service list l

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8612100045 861204 PDR ADOCK 05000445 G PDR .

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.m TRIAL l.AWYERS FOR PUBLIC JUSTICE. P.C.

COUN5tLLORS AT LAW SUITE 6ll 2000 P STREET. NORTHWEST ANTHONY t RossMAN WASHINGTON. D C. 20036 (AICuTI%1 DIRiC TOR (202)463-8600

,.RTHUR BRYANT Sf/Jf ATTORNEY BILut GARDI DIREC TOR. ENVIRONMENTAL WHI5fLIBLOW1R PROllCT BAR8 ARA PRATT m'Ct mANactR December 4, 1986 N.ATHLtEN CUMBERBATCH SECRtfARY Victor Stello BY HAND Executive Director of Operations U.. S . Nur: lear Regulatory Commission 7735 Old Georgetown Road, 6th floor Bethesda, MD 20814 RE: _ Texas Utilities Electric Co. (Comanche Peak)

Dkt. Nos. 50-445, 446-OL and 50-445-CPA

Dear Mr. Stello:

Pursuant to 10 CFR 52.744 and on behalf of Citizens Association for Sound Energy (CASE), I hereby request that you produce immediately the recently completed OIA report, with all attachments, draf ts, depositions, and documents, relating to the performance of Region IV in its evaluations of the Comanche Peak Steam Electric Station. It is my understanding that this document and its attachments contain substantial evidence relating to the inadequacy of the quality assurance / quality control program in effect at Comanche Peak during its construction as well as informatin regarding the failure of Region IV to report or disclose these deficiencies. Inasmuch as the pending licensing and construction permit amendment proceedings both involve questions of QA/QC adequacy during construction of Comanche Peak, and the OL proceeding involves the question of Region IV's performance and its implications for workers who felt haracsment and intimidation and could not go to the NRC~with their concerns, there can be no doubt that this report is highly relevant to both proceedings.

Because there are several motions now pending in both proceedings to which this information is relevant, I request that you release the documents no later than 4:00 p.m., Friday, December 5. Failure to receive a response f rom you by then will be deemed equivalent to a denial within the meaning of S2.744(c),

and we will proceed accordingly. You may provide your response by telephone and make a copy of the documents available at your offices for our pickup. If I am unavailable at the above number, please contact my co-counsel Billie Garde at (202)232-8550.

Sincerely,

,h&$ =__m vAnthony Z o man AZR/bp cc: service list (by mail)

Larry Chandler (by hand)