ML20128G835

Memorandum Objecting to Case 850329 Request That Applicant Suppl Prior Document Productions.Documents Will Be Made Available for Insp & Reproduction on 850524.Certificate of Svc Encl

ML20128G835
Person / Time
Site:	Comanche Peak
Issue date:	05/29/1985
From:	Downey B BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#285-173 OL-2, NUDOCS 8505300326
Download: ML20128G835 (5)

Text

l73 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CCCKETED UStiRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARDS 5 MAY 29 P3:45 ,

In the Matter of ) LFFICE OF SECREit#1

) Docket Nos. 50-44 sC2(EgyERV!U. .

TEXAS UTILITIES ELECTRIC ) 50-446-2 COMPANY, et al.

)

) (Application for (Comanche Peak Steam Electric') Operating Licenses)

Station, Units 1 and 2) )

APPLICANTS' MEMORANDUM REGARDING SUPPLEMENTAL DOCUMENT PRODUCTION By letter dated March 29, 1985 Citizens Association for Sound Energy (CASE) requested that Applicants supplement their prior document productions in this Docket. This request spe-cifically sought, intra alia, all documents, OAI files, exit interviews, hot line investigations, and SAFETEAM reports prepared since Applicants' last document production that re-late to alleged incidents of harassment and intimidation which occurred prior to July 1, 1984. With the exceptions noted below, all such documents will be made available for inspec-tion and copying at the office of Counsel for Applicants on May 24, 1985. Representatives of Intervenor wishing to review the documents at times other than that set forth above should contact Counsel for Applicants.

8505300326 850529 hDR ADOCK 05000445 PDR

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i OBJECTIONS TO-PRODUCTION

1. Applicants' SAFETEAM files contain one responsive report. Applicants object to the production of this document on the grounds that the individual raising the matters ad-dressed in the report requested confidentiality. In addition, one responsive QAI file concerns matters raised by an individ-ual who has requested confidentiality and on that basis Appli-

-cants also obj ect to its production. Applicants, however, will make these documents available to . CASE if CASE's repre-sentatives agree to treat the information in the documents in accordance with the Protective Order in effect in this pro-

.ceeding.

2. - Applicants also object to the production of all docu -

'ments within 'the scope of Intervenor's request that were pre-pared by and at the direction of counsel. Such' documents

. include notes, letters,- memoranda, draf tLpleadings, summaries of testimony and the like prepared in anticipation of and during the hearings in this matter.

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.i I 3. Finally, Applicants object to the production of cer-tain portions of QAI-003 on the grounds that such portions of the OAI are comprised of advise provided by Counsel. Appli-cants have provided the balance of QAI-003.

Respectfully submitted, h N BrDce~ LT Do'99 69 "

Counsel for Applicants Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9800 May 29, 1985 t

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UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION COLAETEC BEFORE THE ATOMIC SAFETY AND LICENSING BOAEb In the Matter of )

) Docket Nos. 50-445-2 and TEXAS UTILITIES ELECTRIC ) $0d446'gC"t*D 00CKEl COMPANY, ET AL. ) BRANC

) (Application for (Comanche Peak Steeth Electric ) Operating Licenses)

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' Memorandum Regarding Supplemental Document Production, in the above-captioned matter was served upon the following persons by deposit in the United States mail, first class, postage prepaid or by hand delivery (*) on this 29th day of May, 1985.

• Peter B. Bloch, Esquire Chairman, Atomic Safety Chairman, Atomic Salty cnd and Licensing Appeal Licensing Board Panel U.S.' Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Walter H. Jordar.

• Mr. William L. Clements 881 West Outer Drive Docket and Service Oak Ridge, Tennessee 37830 Branch U.S. Nuclear Regulatory Commistion Washington, D.C. 20555 Dr. Kenneth A. McCollom

• Stuart A. Treby, Esquire Dean, Division of. Office of the Executive Engineering, Architecture Director

~and Technology U.S. Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C. 20555

t

• Herbert Grosman

• Ellen Ginsberg, Esq.

Alternate Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Comission Washington, D.C. 20555 Washington, D.C. 20555 Chairman, Atomic Safety Elizabeth B. Johnson and Licensing Board Oak Ridge National Panel Laboratory U.S. Nuclear Regulatory Post Office Box X Commission Building 3500 Washington, D.C. 20555 Oak Ridge, Tennessee 37830 Robert D. Martin Renea Hicks, Esquire-Regional Administrator, Assistant Attorney General Region IV Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 Suite 1000 Capitol Station 611 Ryan Plaza Drive Austin, Texas 78711 Arlington, Texas 76011 Mrs. Juanita Ellis Lanny A. Sinkin President, CASE Suite 304 1426 South Polk Street 3022 Porter Street Dallas, Texas 75224 Washington, D.C. 20008

• Billie Pirner Garde

• Anthony Z. Roisman, Esq.

Citizens Clinic Director Trial Lawyers for Public Government Accountability Justice Project Suite 611 1901 Que Street, N.W. 2000 P Street, N.W.

Washington, D.C. 20009 Washington, D.C. 20036

• Joseph Gallo, Esq.

Isham, Lincoln & Beale Suite 840 1120 Connecticut Ave., N.W.

Washington, D.C. 20036

$Y o 4(u'c6~L. Bowney cc: John W. Beck Robert A. Wooldridge, Esq.

. . .-