ML20205G981

Forwards Addl Info for Scheduled 851112 Prehearing Conference Re Discovery Matters.Related Correspondence

ML20205G981
Person / Time
Site:	Comanche Peak
Issue date:	11/07/1985
From:	Ellis J Citizens Association for Sound Energy
To:	Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel
Shared Package
ML20205G965	List: ML20205G961 ML20205G981
References
OL, NUDOCS 8511130407
Download: ML20205G981 (5)

Text

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(CITIZENS ASSN. FOR SOUND ENERGY) 214/946-9446

• C November 7,,1985 '85 NOV 12 AH :25 Administrative Judge Peter B. Bloch 0FF!CE y 3ggg g.y Atomic Safety and Licensing Board Chairman U. S. Nuclear Regulatory Commission

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Washington, D. C. 20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830

Dear Administrative Judges:

Subj ect : In the Matter of .

Texas Utilities Ele:tric Company, et al.

Request for an Opernting License for Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445 and 50-446 O L Additional Information for Prehearing Conference Regarding Discovery Matters We are attaching some additional information for the scheduled November 12 prehearing conference regarding discovery matters. .

For easier reference during the prehearing conference, I have marked these as Attachments 4 and 5 to our 10/26/85 (Main Docket) Response to Board's 10/15/85 Request Regarding Discovery Matters.

This should give us a better format from which to further discuss these matters. ,

Respectfully submitted, CASE (Citizens Association for Sound Energy)

, l' /

. rs.) Juanita Ellis, President cc: Service List (Federal Express to Messrs. Reynolds and Gad)

Judge Herbert Grossman 8511130407 851107 PDR 1

• ADOCK 05000445 PDR

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. ATTACHMENT 4 to CASE's 10/26/85 (Main Docket)

Response to Board's 10/15/85 Request Regarding Discovery Matters OBJECTIONS / ISSUES - APPLICANTS' 10/22/85 RESPONSES TO " CASE'S 8/27/85 INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE" Provided below is a listing of specific objections and/or issues with which -

the Board will be asked to deal during the upcoming prehearing conference on discovery matters, in' regard to subject answers by Applicants:

1. Not relevant to Contention 5:

A-2, A-3, A-4 A-5 A-7 A-8 A-9 A-19 A-20 B-3 D-4, D-5 E-6 G-1 (part)

G-2 (part)

2. There is no pending litigation re: adequacy of CPRT Program Plan before the Board; CPRT efforts and personnel are not relevant to Contention 5, etc.

A-6

3. Will only provide when flies ready for inclusion in CPRT Central Files (also answers provided are not responsive to specific questions; don't know if there or not, or where they are)

A-1

'A-11 A-13 (? not clear) .

A-14 (part)

A-15 A-16 A-17 A-18 "

A-19 A-21 1

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ATTACHMElff 4 to CASE's 10/26/85 (Main Docket)

Response.to Board's 10/ 15/85 Request Regarding Disc wery Matters t

e' B-1 (part) ~

B-3 B-5 B-6 B-7 -"

C-1!

c C-2 -"

C-3 C "

C-5 C-6

- ~ D- 1 D-2 D-3 E-26 E-27

'E-28:

E-31 E-34 ,

- s' .E-35 E-36 E-41 C 4. Object to calling for documents not present in existence A-1 A-15 .

B-4 (? - appears to be implied)

5. Object to providing information or doucments arising out of the SAFETEAM program A-5

6. Applicable to Docket 2 (harassment and intimidation)

B-2 2

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[. ATTACHMENT 4 to CASB's 10/26/85 (Main Docket)

' Response to Board's 10/ 15/85 Request Regarding Discovery Matters

7. .Not providing documents in'possesion of Applicants' consultants (?)

.- C-6 .

D-1' E-13 (?)

.E-14 (?)

8. Overly broad, excessively burdensome, overly vague and/or-

. insufficiently specific A-2, A-3, A-4 A-7.

A-11 A-18 E-29 E F-3, F-4

- 9. Attorney / client privilege

- E-34

10. . CASE does not consider answer to be responsive to the question C-1

g. G-2

11. Need additional information, clarification, etc.

E will provide? or where available?

E answer was "[To be supplied.]"

E answer appears to refer back to wrong response E answer - was "[To be provided.]'.'

1 0

3

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ATTACHMENT 5 to CASE's 10/26/85 (Main Docket)

Response to Board's 10/15/85 Request Regarding Discovery Matters OTHER MATTERS

-)ULC Report:

As discussed in the 11/7/85 telephone call between Applicants' Messrs.

Wooldridge and Gad and CASE's Mrs. Ellis, it is CASE's understanding that Applicants will answer all the questions and provide ~~all relevant documents regarding the MAC report as ordered in the Board's 7/22/85 Memorandum and Order (Motions Related to the MAC Report), as well as all~those ordered in the Board's 10/29/85 Memorandum and Order (Status of Pending Motions) (pages

~1 through 3).

As discussed in the 11/7/85 telephone call between Applicants and CASE's Mrs. Ellis, it is CASE's understanding that all of the specific matters set forth at pages 12 and 13 of CASE's 10/26/85 (Main Docket) Response to

-Board's 10/15/85 Request Regarding Discovery Matters are to be included in the 11/12/85 prehearing conference on discovery.

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