ML20098E704

Motion for Production of Documents Re Proposed Testimony of Eg&G.Certificate of Svc Encl.Related Correspondence

ML20098E704
Person / Time
Site:	Comanche Peak
Issue date:	09/26/1984
From:	Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#484-118 OL-2, NUDOCS 8410010301
Download: ML20098E704 (5)

Text

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gagSPONDENW Septehkh6,1984 UNITED STATES OF AMERICA '84 SD3 28 A11:23

, NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BbNIbbg,, h j

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In the Matter of )

,, )  ;

TEXAS UTILITIES GENERATING )

COMPANY, et al. )

)

Docket Nos. 50-445-2 and 50-446-2 g)[_((,

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

Y CASE'S MOTION FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF REGARDING PROPOSED TESTIMONY OF EGEG */

1. Please produce a copy of all written communications **/

Detween any person at the NRC and any of the persons:

a. who worked on developing the scope of work and goals of the contract which resulted in the EG&G report; '

O. who worked on the preparation of the report in any capacity; T

• / All requests for documents include documents in the possession of NRC, its contractor (EG&G) and any persons employed Dy its contractor in conjunction with preparation of the EGEG report.

5

- **/ Written communications as used in this Motion include, but

.are not limited to, notes of meetings or phone calls, draf t reports and/or comments thereon, handwritten notes, word =

processor diskettes and tape recordings if the material contained 3 on the diskettes or tape is not in hard copy, corputer programs and any printouts used in conjunction with those programs.

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c. who nave been'br will De consulted by the NRC for

) ~ purposes of analyzing the report and preparing for or suositting testimony with respect to the report.

2. Please produce a copy of all written communications Detween any NRC employees regarding the development of the h contract for the BG&G report, the progress on completing the '

work, the draft and final work products and the subject matter of the report itself. Also produce any drafts of the EGEG report or 1

- proposed changes or modifications of the EG&G report prepared by )

any NRC employee, 'any NRC contractor, or any employee of any NRC 5 '

contractor.

3. Please produce a copy of all materials examined or relied upon in formulating the views expressed in the EGEG

.- - report. To the extent any material is already a part of the k}

record of this case an identification of the material, where

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it appears in the record and for what portion of the report it was relied upon will be sufficient.

2-I 4. With respect to the EGEG report please produce a copy of all written notes, draf ts, calculations, or any other 7

- documents prepared by any person who participated in the preparation of the EG&G report or participated in the preparation p

s of any of the materials examined or relied upon in preparing the 0.

71 report.

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5. Identify oy name, address and phone number, and provide a curriculum vita for every person who participated in any way in the preparation of the EG&G report and indicate what work was done Dy them.

6. Please produce a copy of all written communications netween any NRC employee or any EGEG employee or any person used Dy the NRC or EG&G for the purpose of working on the EGEG report or the development of data for the report and any other person with respect to the report or its subject matter.

Respectfully submitted, d n N -

u_.

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KNTBONY 2. p Slput Trial Lanfr for PuDlic Justice 2000 P Stre t, N.W., Suite 611 Washington, D.C. 20036 (202) 463-8600 t

U0,hkc Septb[mDer 26, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

pK f;jp: O BEFORE THE ATOMIC SAFETY AND LICENSING?BOARQMcH In the Matter of )

)

TEXAS UTILITIES GENERATING )

COMPANY, et al. ) Docket Nos. 50-445-2

) and 50-446-2 (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE By my signature Delow, I hereby certify that true and correct copies of CASE's Motion For Production of Documents to the NRC Staf f Regarding Proposed Testimony of EG&G have been sent to the names listed Delow this 26th day of September,1984, Dy:

Express mail where Indicated Dy *; Hand-delivery where indicated Dy **; and First Clnss Mail unless otherwise indicated.

Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission 4350 East-West Highway, 4th Floor Bethesda, Maryland 20814 Heroert Grossman Alternate Chairman ASLB Panel U.S. Nuclear Regulatory Commission 4350 East-West Highway, 4th Floor Bethesda, Maryland 20814 Dr. Kenneth A. McCollon, Dean Division of Engineering, Architecture 3_ and Technology Oklahoma State University

}; Stillwater, Oklahoma 74074 i

Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Ms. Ellen Ginsberg, Law Clerk U.S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Bethesda, Maryland 20814 Nicholas S. Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, N.W.

Washing ton, D.C. 20036 Stuart Trecy, Esquire Geary S. Mizuno, Esquire Of fice of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building Room 10105 4350 East / West Highway, 4th Floor Bethesda, Maryland 20814 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General F Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis y President, CASE 1426 S. Polk Dallas, Texas 75224 h

6KNT80NY Z. ROSyN Trial Law er for Public Justice 2000 P S r t, N.W., Suite 611 Washing ton, D.C. 20036 (202) 463-8600

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