ML20005B944

Advises That Documents Per Requests 2,3,4 & 6 Will Be Produced When Info Compiled.Discusses Request 1 & Objects to Request 5.Related Correspondence

ML20005B944
Person / Time
Site:	Dresden
Issue date:	09/03/1981
From:	Fitzgibbons R COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Marc-Anthony Murray ILLINOIS, STATE OF
References
NUDOCS 8109160160
Download: ML20005B944 (2)

Text

lu2.ATED CORRESPOW PROD. & UTi bb' b b b h ISHAM, LINCOLN & BEALE COUNSELORS AT LAW ON E reRST N ATION AL PL AZ A FORTY-SECOND FLOOR CHIC AGO, lLLINOIS 60603 TELERHONE 312 558 7500 TELEX: 2-5288 WASHINGTON OFre;E September 3, 1981 "" c "* 'lJ,',cl',s f""" " * -

WASHINGTON. O. C 20036 BY MESSENGER S 9 =

Ms. Mary Jo Murray 4 Assistant Attorney General -

17.

Environmental Contre 1 Division 7 3 D 151981 w _ ND \

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188 West Randolph Street E' Suite 2315 Chicago, Illinois 60601

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N ' pcigr f-[; O!! ice cf the Secretary Re: Dresden Spent Fuel Poo tion b DxWig a haite Crich -

Dear Mary Jo:

cn We will be producing the documents per your requests Nos. 2, 3, 4 and 6 as soon as we have compiled this informa-tion. With respect to document request No. 1, we have not yet decided whether we will be introducing into evidence any prepared written testimony other than material already We will certainly served on all parties in this proceeding.

be introducing into evidence Commonwealth Edison's initial response to NRC technical questions with accompanying cover letter by Robert F. Janecek, dated and filed June 12, 1981, and subsequent report entitled " Seismic Analysis for Installation of Five and Ten High Density Fuel Racks" submitted to the

! NRC Staff by the letter of T. J. Rausch dated August 10, 1981, which was attached to the "NRC Staff Response to Applicant's Motion For A Partial Initial Decision," filed and served upon all parties in this proceeding August 13,

! 1981. I am currently investigating whether there are earlier drafts of these reports. We will be providing the working papers for these reports per your document request No. 2. Unfortunately the NSC/Quadrex Staff individual who conducted these analyses will be on vacation until September 8, 1981. We will provide these working papers as soon as we can gain access to them. In addition, our witnesses will be prepared to answer any questions the Licensing Board members l

may wish to raise. We do not anticipate preparing any written testimony on such questions, but any written preparation l

for such questions would fall within the scope of the attorney-client and work product privileges.

We object to document request No. 5 (Intervenor's contentions, Board question, and Fuel Channel Bowing). The record is closed with respect to these issues and no further evidentiary presentation will be made on these issues.

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At this time we anticipate that the only witnesses we will be presenting at the hearing will be Messrs. Robert Janecek and Quasi Hossain. Robert Janecek is an employee ,

with Commonwealth Edicon Company whose credentials were attached with his affidavit submitted earlier in this proceeding.

Quasi Hossain is an employee of Quadrex/NSC. We will include both individuals' credentials in the material to be produced, although Mr. Hessain's credentials were included with his testimony in the Zion case, so you should already have a copy.

Naturally, any confidential material obtained from Quadrex/NSC will be produced subject to the terms of the proprietary agreement you entered into earlier in this proceeding.

Per our telephone conversation of September 2, 1981, I am requesting that you provide me with the following:

1. A list of all witnesses who may or will testify at the hearing, including their qualifications, expertise and the subject matter on which they will testify;

2. All documents containing analyses, or conservatisms which the State of Illinois contends should be required to be employed in such analyses, which l

will be submitted as, or are the basis for testimony l which will be submitted orally or in writing at the hearing.

If ye" have any additional comments or questions, please don't hesitate to call either Phil Steptoe or myself.

Sincerely,

,. . .(c , ,

Robert G. Pi'tzgibbons, Jr. j' One of the Attorneys for Commonwealth Edison Company RGF:kj ,

cc: Service List