ML19345H104

Response to Citizens for Fair Util Regulation 810324 First Set of Requests for Production of Documents.Lists Documents Applicants Will Produce.Certificate of Svc Encl.Related Correspondence

ML19345H104
Person / Time
Site:	Comanche Peak
Issue date:	04/28/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	CITIZENS FOR FAIR UTILITY REGULATION
References
NUDOCS 8104300500
Download: ML19345H104 (5)

Text

.

?"MJ2 CORRESPONDENCE

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,$ J- }' L April 28, 1981

$ APR 2 91981* ',' l

( u.a. m eaam 1 ,

UNITED STATES OF AMERICA e NUCLEAR REGULATORY COMMISSION ut; FORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

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

)

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

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9 Doe *-- w 9 0.6 APPLICANTS' RESPOhSE TO CFUR' S  %

t FIRST SET OF REQUESTS FOR O APlt 2 938 PRODUCTION OF DOCUMENTS & -

. ice of the Secret y nocheting 4 servie,

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Brance Pursuant to 10 C.F.R. 52.741(d), Texas Utilitiet N 6, Generating Company, et al. (" Applicants") hereby submit

• their response to the request for production of documents set forth in the "First Set of Interrogatories to Applicant (sic] and Requests to Produce" served by Citizens for Fair i

Utility Regulaticn ("CFUR") on March 24, 1981. Applicants 1

i served their answers to CFUR's interrogatories on April 13, 1981. Applicants also set forth below the procedures for inspection and copying of the documents requested by CFUR.

JP 5Oh 9*I 8104 3 a n gcc

Applicants Response to CFUR's Request To Produce CFUR's request to produce is identified by the item number corresponding to the number in "CFUR's First Set of Interrogatories to Applicant [ sic] and Requests to Produce. "

19. Applicants will provide for inspection and copying applicable portions of the following documents:

- (1) Contract between the Applicants and Westinghouse for purchase of the Nuclear Steam Supply System, .

Contract CP-1000, dated October 6,1972.

(2) Contract between the Applicants and Westinghouse

, regarding nuclear fuel, Contract CP-5000,

! dated May 11, 1973.

l l (3) Agreement of Settlement between the Applicants

~

and Westinghouse, dated December 16, 1977.

[This is the proper date for the Agreement of Settlement to which CFUR refers in its inter-rogatories. Applicants do not know how CFUR arrived at the December 27, 1977 date which it uses.]

l Procedures For Inspection And Copying CFUR may inspect and copy the documents identified above according to the following procedures:

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1. The documents identified above will be available for inspection at the Texas Utilities Generating Company offices, 18th Floor, 2001 Bryan Tower, Dallas, Texas, during normal business hours (8:00 a.m. to 5 :00 p.m. , Monday through Friday) .

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

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

Respect y submitted, I

)

I H Nichola y. Reynolds

• J William A. Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202)857-9817 Counsel for Applicants April 28, 1981

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, et al.

) 50-446

)

(Comanche Peak Steam Electric ) (Application for -

Station, Units 1 and 2) ) Operating License) t l

CERTIFICATE OF SERVICE l I hereby certify that copies of the foregoing " Applicants' l

Response to CFUR's First Set of Requests for Production l

of Documents" in the above captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 28th day of April, 1981:

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 l 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 l

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

4, 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. M:i. Chase R. Stephens 4021 Prescott Avenue Docketing & Service Branch

)

Dallas, Texas 75219 U.S. Nuclear Regulatory Commission Mrs. Juanita Ellis Washington, D.C. 20555 Pres ident, CASE 1426 South Polk Street Dallas, Texas 75224 William A. Horin I

cca Homer C. Schmidt Spencer C. Relyer., Esq.

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