ML20214P886

Notice of Deposition of J Rushwick in Dallas,Tx Immediately Following Deposition by Head of Sseg.Related Correspondence

ML20214P886
Person / Time
Site:	Comanche Peak
Issue date:	09/18/1986
From:	Garde B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Shared Package
ML20214P697	List: ML20214P694 ML20214P701 ML20214P710 ML20214P728 ML20214P764 ML20214P773 ML20214P784 ML20214P803 ML20214P824 ML20214P848 ML20214P866 ML20214P886 ML20214P896 ML20214P904 ML20214P924 ML20214P930
References
OL, NUDOCS 8609240087
Download: ML20214P886 (3)

Text

~

occonew616ift COL KEitT BEFORS Td8 USNRC ONITED STATBS NUCLBAR REGULATORY COMMISSION

) 16 SD' 22 P1 :14 Before tne Atomic Safety ana Licensing Board 0FFICE 06 S f '. t i A P f 00CKEilNG & SLFvlCf.

) in rne Matter or ) BRANCH

)

TEXAS UTILITIES G6NSRATING COMPANY, ) Dkt. Nos. 50-443-OL et al. ) 50-446-OL

)

(Comanene Peak Steam diectric )

Station, Units 1 ano 2) )

NOTICE OF DEPOSITION Intervenor CAS8, pursuant to Rule 30(b) or the Feaeral Rules or Civil Procedure ano 10 CFR 432.720 and 74Ua, nereby provides notice tnat, immealately following tne deposition of the .5ead or SSEG, intervenor will take the aeposition upon oral examination or John RusnwicK. The deposition will De held in Dallas, Texas, at the offices of Frederick daron & Associates, Suite 1400, Dallas Federal Savings Building, 8333 Douglas Avenue, Dallas 73243.

Tne ceposition will continue from aay to day until completeo, suoject to such adjournment as may oe agreea upon by Counsel.

Mr. Rusnwick is also airected to oring to the deposition, as inoicatea oy the enclosea suopoena, all accuments in nis custody or possession (or unoer his control) that refer or relate in any way to:

(1) Tne selection process usea for personnel performing the talro party activities.

8609240087 860918 PDR ADOCK 05000445 G PDR

(2) All preliminary assessments done in the electrical area to cetermine root cause ana generic implications.

)

(J) uevelopment of the action plans for the various ISAPs.

(4) The Applicants' responses to the comments ana

)

recommenuations or the NRC in revising the action plans.

(5) Otner auties as descrioea on pages 21-22 of the CPRT.

"uocumen t" shall mean every instrument or aevice oy wnich, througn wnich, or on which information has been recordea, incluainy those reflecting meetings, discussions, or conversations; notes; letters; drawings; files; grapns;; charts; maps; pnotographs; oeeos; studies; data sheets; noteoooks; books; appointment calenaars; telepnone bills; telephone messages; receipts; vouchers; minutes of meetings; pamphlets; computations; calculations; accounting (s); financial statements; voice recordings; computer printouts; and any device or medium on which or through which information of any type is transmitted, recoraea, or preserved. The term " document" also means every copy of a document when such copy is not an identical duplicate or the original.

Counsel for intervenor will asK Mr. Rushwick to identiff each document produced in response to tne enclosea subpoena and counsel may examine Mr. Rushwick concerning the contents ot the oocuments produced.

Counsel for intervenor will examine Mr. Rushwick on all matters relevant to the adequacy of the CPRT and tne above mentioned matters and all explanations given Dy Applicants.

w- -w--- r --- -

,.% - ,--z ,-m- --- r

,\

Respectfully suomittea,

/) ,

f BILLIE P. GARDE Trial Lawyers for Public Justice 3424 North Marcos Lane Appleton, WI 54911 Counsel for CASE Datea: September 18, 1980

- _ _ _