ML19345G876

Response to Applicant Second Set of Interrogatories.Related Correspondence

ML19345G876
Person / Time
Site:	Byron, Comanche Peak
Issue date:	04/13/1981
From:	CITIZENS FOR FAIR UTILITY REGULATION
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML19345G875	List: ML19345G874 ML19345G876
References
NUDOCS 8104220599
Download: ML19345G876 (2)

Text

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p RELATED CORRESPONDENCE 4

Dmarre s UNITED STATES OF AMERICA [- Apg y NUCLEAR REGULATORY COMMISSION Cj :',:  ;;,. 2, y . . ~..::

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g 4 y or >

In the Matter of ) Docket Nos. 50-445 - -

TEXAS UTILITIES GENERATING )

COMPANY, et al

--~--

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

CFUR'S RESPONSE TO APPLICANT'S SECOND SET OF INTERROGATORIES 1-2. The words of Contention 1 are intended to have their

" plain meaning". See also CFUR's Answers to Staff Interroga-tories Cl-1, Cl-2.

2-2. The basis for Contention 1 can be found in (a) Supplement g to Petition for Leave to Intervene by Citizens for Fair Utility Regulations (CFUR), May 7, 1979; and (b) Transcript, Prehearing Conference, April 30, 1980.

l 3-2. No. ,

4-2. No.

~

5-2. Persons associated with CFUR have met with persons associated with other intervening parties, as well as with l persons associated with Applicants and the Staff. While -

, matters touching Contention 1 may have been discussed, none of these meetings was for the purpose of discussing Contention 1 and nothing pertaining to Contention 1 resulted therefrom.

l 6-2. None other than the hearing process.

i

! 7-2. Yes. The full extent of CFUR's participation is unknown l

at this time.

8-2. Not at this time.

3-2. Not at this time.

10-2. Not applicable.

l 11-2. See CFUR's Answers to Staff Interrogatories Cl-5.

.12- 2 . Not applicable, 13-2. See CFUR's Answers to Staff Interrogatories Cl-3.

f

' '8104 2 2 05ct9

, . . . . . . - ; m .. .: = = - _ ... .. . =...~. _ .. ..

. -n 14-2. See CFUR's Answers to Staff Interrogatories Cl-3.

15-2. See answer to 2-2 above.

16-2. See CFUR's Answer to Applicant's First Set of Interro-gatories, Interrogatory 11-2.

17-2. Same as 16-2 above.

6 18-2. Same as.16-2 above.

19-2. Same as 16-2 above.

20-2. Same as 16-2 above.

i 21-2. See CFUR's Answers to Staff Interrogatories Cl-7.

22-2. See CFUR's Answers to Staff Interrogatories Cl-7; and also the answer to 2-2 above.

23-2. No. .

l 24-2. Not applicable.

25-2. Applicants are required to supply all information and

, analyses relating to safe operation, training, and maintenance, etc. of C.P.S.E.S. under all circumstances.

l 26-2. 10 C.F.R. Part 50.57(a).

27-2. CFUR is unable to understand this overly general and

, hypothetical question; therefore, CFUR is unable to formulate a meaningful response.

28-2; Not applicable.

29-2. Not applicable.

30-2. Not applicable.

31-2. Yes.

32-2. See answer to 11-2 above.

33-2. See answer to 11-2 above.

34-2. See answer to 11-2 above.

35-2. No.

36-2 Not applicable 37-2 See CFUR's Answers to Staff Interrogatories Cl-7.

38-2. 10 C.F.R. Part 50.57(a).

? .

39-2. See answer to 2-2 above.

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