ML19347D772

Response to Citizens Association for Sound Energy Requests for Production of Documents Contained in 810217 Fourth Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML19347D772
Person / Time
Site:	Comanche Peak
Issue date:	03/24/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
NUDOCS 8103270536
Download: ML19347D772 (5)

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• UNITED STATES OF AMERICA >

) b NUCLEAR REGULATORY COMMISSICS - *- '

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2: * '34 - RE THE ATOMIC SAFETY AND LICENSING BOARD 'N .f i

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In the Matter of )

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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)

, APPLICANTS' RESPONSE TO CASE'S l

REQUESTS FOR PRODUCTION OF DOCUMENTS l

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l Pursuant to 10 C . F . R . 2.741(d), Texas Utilities Generating Company, et al. (" Applicants") hereby submit l

l Applicants' response to CASE's requests for production of l documents as set forth in " CASE's Fourth Set of Interroga-l tories to Applicants and Requests to Produce," dated

February 17, 1081. Applicants also set forth belcw the i

i procedures for inspection and copying of the documents requested by CASE.

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l Aeolicants' Resconses to Recuests to Produce l Each request to produce is identified by item m.:mber, corresponding to the numbers in " CASE's Fourth Set of l

Interrogatories to Applicants and Requests to Produce." .

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Contention 25 2(b). The " Comanche Peak Steam Electric Station--

Application for Operating License" should be available in the local NRC Public Documents Rooms . If CASE is unable to locate a copy of the Application at the PDRs, Applicants will make a copy available for inspection and copying pursuant to the procedures set forth below. In addition, as indicated in Appli-cants' answe- to interrogatory 2 (c) , Appli-cants have also provided to the NRC current annual financial reports. Copies of these ,

reports will be made available for inspection and copying pursuant to the procedures set forth below.

11. See response to 2(b).

Contention 22 As Applicants indicated in their March 9, 1981 Answers to CASE's Fourth Set of Interrogatories, "not applicable" responses to the following requests to produce rendered production of any documents unnecessary: Questions 17(g) and (i); 18(b) and (h); 19(d)(3), (e)(3), ( f) (3 ) , (g)(3),

(8), (9) and (10), h(2), and i(3).

Also, as indicated in Applicants' March 9, 1981 Answers, documents requested in question 19(c) do not exist.

Procedures for Inspection and Copying CASE n.ay inspect and copy the documents identified above acco:: ding to the following procedures:

1. The documents identified above will be -

available for inspection at the Texas Utilities Generating Company offices,

l LBth Flect, 2001 3ryan Tcwer, Callas, Texas, during normal business hcurs (8:00 a.=. to 5:00 .u.=., Mendav throuc.h Friday).

2. CASE should schedule inspection of documents by notifying Ec=er C. Sch=idt, at (214) 653-4782,

who will arrange for the docunents to be inspected.

3. CASE should not re=cve any documents frc:

the rec = provided for such inspection. CASE should identify those documents it wishes ~

to be copied and Applicants will =ake and supply copies at CASE's expense and at a rate of 15 cents per page.

Respectfdly sub=itted, h

Nichol s M. Reyncids l l l

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W1111a= A. Horin DEBEVOISE & LIBERMAN 1200 - 17th Street, N.W.

Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants March 24, 1981

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

TEXAS UTILITIES GENERATINO ) Docke t No s . 50-445 COMPANY, et- al. ) 50-446

)

':manche Peak Steam Electric ) (Application for S ta cion, Units 1 and 2) ) Operating License)

I CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Response to CASE's Requests for Production of Documents," in the above captioned matter were served upon the following per.v 7s by deposit in the United States mail, first class postage prepaid l this 24th day of March, 1981:

Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Psnel Licensing Board U.S. Nuclear Regule*;ry 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 l 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 l U.S. Nuclear Regulatory Environmental Protection l Commiss ion Division l Washingten, D.C. 20555 P.O. Box 12548 j Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel l U.S. Nuclear Regulatory Mr. Richard L. Fouke l Commission CFUR -

Washington, D.C. 20555 1668B Carter Drive Arlington, Texas 76010 I

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i Arch C. McColl, III, Esq. Mr. Geoffrey M. Gav 701 Cctmerce Stree: West Texas Legal Services

, Suite 302 100 Main Street (Lawyers Elde.)

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Dallas, Texas 75202 Fort Wor-h, Texas 76102 Jeffery L. Eart, Esq. Mr. Chase R. Ste= hens 4021 Prescott Avenue Docketinc & Serv' ice Branch U.S. Nuciear Regulatory i

Dallas, Texas 75219 Ccm=ission Mrs. Juanita Ellis Washing:cn, D.C. 20555 President, CASE 1426 South Folk Street Dallas, Texas 75224 _

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William A. Horin ec: Ecmer C. Schmidt Spencer C. Relyea, Esq.

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