ML19329D501

Responds to 730621 Document Request & Forwards Applicants' Answers to Coalition for Safe Electric Power'S 730621 Interrogatories

ML19329D501
Person / Time
Site:	Davis Besse
Issue date:	07/05/1973
From:	Silberg J SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Baron R BRANNON, TICKTIN, BARON & MANCINI
Shared Package
ML19329D502	List: ML19329D501 ML19329D503
References
NUDOCS 8003120763
Download: ML19329D501 (3)

Text

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. SHAW. PITTMAN, POTTS & TRoWBRIDGE

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Brannon, Ticktin, Baron & Mancini 930 Keith Building Cleveland, Ohio 44115 Re: The Toledo Edison Company and The Cleveland Electric Illutninating Company (Davis-Besse Nuclear Power Station) , Docket No. 50-346

Dear Russell:

Enclosed are Applicants' answers to interrogatories submitted by the Coalition for Safe Electric Power on June 21, 1973. The interrogatories were modified by a document entitled Clarification of Intervenor's Interrogatories to Applicants, submitted by the Coalition on June 28, 1973, and further modified at the Prehearing Conference of June 28, 1973 (Tr. 121-126). Additional clarifications were provided to me by Mrs. Stebbins in telephone conversations on June 29 and July 2, 1973. The answers are set forth in the enclosed Affidavit of Lowell Roe.

As you recognized in your June 21, 1973 submittal, (p. 10), some of the interrogatories and requests for documents had previously been requested by Mrs. Stebbins. In my letter to you of June 15, 1973, Applicants provided responses to Issue 2, Nos. 13 and 21, and Issue 8, No. 1. My letter to you of June 20, 1973 provided Applicents' responses to Issue 1, Nos. 2, 2 (a) , 17, 18, and Issue 2, Nos. 1, 1(a) , 3, 4, 8, 11, 14, 15, 20, 23, 33. Applicants' response to Issue 8, No. 4, was provided by Mr. Lowell Roe to Mrs. Stebbins on June 12, 1973.

l Applicaats' answers reflect the fact that the l Coalition withdrew the following interrogatories at the l June 28, 1973 Prehearing Conference: Issue 1, Nos. 10, i

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Russell Z. Baron, Esq.

July 5, 1973

,. Page Two 11 and 32; Issue 3, No. 5; and Issue 4, No. 7. In our July 2, 1973 telephone conversation, Mrs. Stebbins sub-mitted a restated version of Issue 2, No. 22. As you recall, this interrogatory as originally submitted was withdrawn at the Prehearing Conference.

With respect to the requests for documents set forth in your June 21, 1973 submission, the follow-ing documents will be made available for your inspection at the offices of either Toledo Edison or Cleveland Electrtc, whichever is more convenient for you. Please call F.r. Lowell Roe at Toledo Edison, (419) 259-5370, to make necessary arrangements.

1. Issue 1, No. 1: Copies of Federal Power Commission Annual Summary Reports of 1970, 19 71 and 197 2.

2. Issue 1, No. 16: Copy of text for slide presentation for nuclear program.

3. Issue 1. No. 20: Complete lists of all present and proposed electric rates.

4. Issue 1, No. 23: Studies identified in Applicants' response to this item relating to relationship of use of electricity to rates paid.

5. Issue 1, No. 28: . Materials distributed to schools, libraries and the public.

6. Issue 1, No. 26 (e) : Materials distrib-uted by Industrial Development Depart-ment.

7. Issue 4, No. 2: Documents relating to fuel rod failures.

8. Issue 5, No. 7: Studies on currents in the western basin of Lake Erie identified in Applicants ' response to this item. (Applicants do not l

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Russell Z. Baron, Esq.

July 5, 1973 Page Three have the four papers by Dr. Herdendorf identified in the answer to this item; these are available at the Center for Lake Erie Research, The Ohio State University, Columbus , Ohio.)

9. Issue 8, No. 2: Studies on the water quality of Lake Erie identified in Applicants' response to this item.

Your June 21, 1973 submission (Issue 2, Nos.

9, 10 and 22) also asked for permission to speak to various persons to be identified by Applicants in their response to those interrogatories. Should you wish to speak to the individuals identified in the answe'rs to Issue 2, Nos. 9 and 22, please contact Mr. Lowell Roe to make the necessary arrangements.

Very truly you ,

J y/E. f;ilberg Enclosures cc: Mr. Frank Karas JC.n B. Farmakides, Esq.

Dr. Cadet H. Hand, Jr.

Mr. Frederick J. Shon Francis X. Davis, Esq.

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