ML19332A192

Response to Citizens Association for Sound Energy Request for Production of Documents Contained in 800707 First Set of Interrogatories.Matls Will Be Available for Insp & Copying Upon Arrangement W/Hc Schmidt.Certificate of Svc Encl

ML19332A192
Person / Time
Site:	Comanche Peak
Issue date:	09/08/1980
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
ISSUANCES-OL, NUDOCS 8009110048
Download: ML19332A192 (5)

Text

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Y f b UNITED STATES OF AMERICA ik4 g (ta9 yg44 NUCLEAR REGULATORY COMMISSION 4*-e 7'.

As f-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

APPLICANTS' RESPONSE TO CASE'S REQUESTS FOR PRODUCTION OF DOCUMENTS AS CLARIFIED BY CASE Pursuant to 10 C.F.R S2.741(d) , Texas Utilities Generating Company, et al., (" Applicants") hereby submit Applicants' Response to " CASE's First Set of Interroga-tories to Applicant," dated July 7, 1980, with respect to those requests to produce as to which Applicants sought ,

l clarification in their " Answers to CASE's Interrogatories,"

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dated July 28, 1980. CASE clarified those requests in its'

" Response to and Motion Regarding Applicants' Answers,"

dated August 4, 1980. The procedures for inspection and l

l copying of the documents requested by CASE are set forth in " Applicants' Response to CASE's Requests for Production of Documents,". dated August 11, 1980 and are set forth again below.

,8009110 0 9 6

0 Applicants' Responses To Requests To Produce Each request to produce is identified by item number,

- corresponding to the numbers in " CASE's First Set of Interrogatories to Applicants," dated July'7, 1980.

1

! Contention 5 Question:

)

i 3. Supply copies of each and every Field Request for Engineering Action (FREA) log.

5. Supply copies of each and every Concrete Pour log.

9. How many audits have been performed by insurers (industrial risk, builder's risk, etc.) on work done i

at the Comanche Peak plant?

10. How many outside or sub-contractor evaluations, studies or audits have been conducted (by sub-contractors or agents of sub-contractors or by consulting firms or i

! others, etc. ) ?

11. Regarding items 8 through 10, provide the following information:

(d) Where is the audit, evaluation, or study kept so that we can review it?

[Regarding Items 9 and 10]

Answer:

Applicants will produce for inspection and copying the documents within the scope of the above requests for production of documents, as clarified by CASE, according l

l l

l

' l 1 .to the following procedures':

1. The documents identified above will be provided for inspection at the Texas Utilities Generating Company offices, 18th Floor, 2001 Bryan Tower, Dallas, Texas, during normal business hours (8 a.m. - 5 p.m., Monday - Friday).

2. CASE should schedule inspection of documents by notifying Homer C. Schmidt, at (214) 653-4782, who will arrange for documents to be inspected.

3. CASE should not remove any documents from the room provided for such inspection. CASE should identify those documents it wishes to be copied and Applicants will make and supply copies at CASE's expense and at a rate of 15 cents per page.

Respec u y s bmitted, s

(' A-Nicho:) .I Reynolds c) .

William A. Horin Debevoise & Liberman 1200 Seventeenth Street, N.W.

Suite 700 Washington, D.C. 20036 l

I (202) 857-9817 Counsel for Applicants September 8, 1980 l

1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY , _e t _al .

) 50-446 (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing

" Applicants' Response to CASE's Requests for Production of Documents as Clarified by CASE", in the above captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 8th day of September, 1980:

Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.

Atomic Safety and Licensing Office of the Executive .

Board Legal Director 305 E. Hamilton Avenue U.S. Nuclear Regulatory State College, Pennsylvania 16801 Commission Washington, D.C. 20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq.

Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548

! Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory Mr. Richard L. Fouke Commission CFUR Washington, D.C. 20555 1668B Carter Drive Arlington, Texas 76010 l

2-Arch C. McColl, III, Esq. Mr. Geoffrey M. Gay 701 Commerce Street West Texas Legal Services Suite 302 100 Main Street ~(Lawyers Bldg.)

Dallas, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq. Mr. Chase R. Stephens 4021 Prescott Avenue Docketing & Service Branch-Dallas, Texas 75219 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Mrs. Juanita Ellis

President, CASE 1426 South Polk Street Dallas, Texas 75224 J -

William A. Horin cc: Homer C. Schmidt

Spencer C. Relyea, Esq.

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