ML20214R799
| ML20214R799 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/16/1986 |
| From: | Garde B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20214R802 | List: |
| References | |
| CON-#386-809 OL, NUDOCS 8609290283 | |
| Download: ML20214R799 (3) | |
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00CMETED USNRC UNITED STATES OF AMERICA NUCLSAR R8GULATORY COMMISSION T6 SEP 16 A11:00 SEFORB TH8 ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
)
l' fdXAS OTILITIES GEN 8 RAT 1dG
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COMPANY, et al.
) Docket Nos. 5U-445 O L N
J 50-446 (Comanche Peak Steam 81ectric
)
Station, Units 1 & 2
)
INTRODUCTION CAS8'S INT 8RROGATORIES AND REQUESTS FOR DOCUMENT PRODUCTION ON THE AD600ACY OF THS COMANCh8 PEAK RESPONSB TEAM (CPRT DISCOVSRY)
The actachea interrogatories and requests for cocument production relate to the adequacy or the Comanche Peak Response l
Team Plan (CPRT).
These questions and document requests are filed j
pursuant to the Boara's Order of August 19, 1986 setting forth a senedule ror the parties to the operating licensing proceeding ror discovery on a limited set of issues related to the adequacy ot the CPRT.
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CASE nas set forth precise instructions for tnese interrogatories and document requests in i separate document.
Tne requests will oe riled in seve q> i (
,5 or which tne attacned sets are tne tirst installment.
The last installment will De riled no later tnan deptemoer 16.
bacn request will oe 8609290283 860916 PDR ADOCK 05000445 C
PDR 0303
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specifically designated "CPRT Discovery - 1, 2,
e tc." Lc clearly distinguish it from other CASE discovery.
Each request also seexs production of the documents wnich are specifically identified in response to a question or examined and/or relied upon in providins any answer.
CA88 will also file requests for several depositions.
The requests will be filed on or before September i8.
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depositions will oe scheduled for a mutually agreeaole time shortly after the answers to the relevant interrogatories are received.
Along with this first set or interrogatories is a set entitled " Definitions."
In this set CASE requests that the Applicants provide. a precise definition to a word or a phrase used in the CPRT.
CASd will then assume that whenever the phrase or woro is usea in their answers or in ref erence to the CPRT l
Applicants mean what the definition provided states unless an alternate definition is provided for tnat use.
CASE seeks to accurately and completely understand the CPRT program.
This task is, understandably, complicated of the normal restrictions or the English language and the amoiguity of tne worcs and phrases useu in the CPRT.
For this reason CASE proposes tnat Applicants meet witn CASE representatives in washington, D.C.
to discuss any or the questions or requests which appear to 'e confusing or unclear shortly after Applicants o
receive the requests. Should the staf t or one or more memoers of the Board want to attend sucn a clarification meeting, CASE has no objection.
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i Respectfully suoinitted, i
BILLIE P. GARDS TRIAL LAWYERS FOR PUBLIC JUSTICE 2000 P Street, N.W.
Suite 611 Washington, D.C. 20036 l
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