ML20004F727

Responses to Citizens for Fair Util Regulation 810513 Fourth Set of Requests for Production of Documents.Applicant Objects to Some Requests & Provides Procedures for Insp of Documents.Certificate of Svc Encl.Related Correspondence

ML20004F727
Person / Time
Site:	Comanche Peak
Issue date:	06/17/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	CITIZENS FOR FAIR UTILITY REGULATION
References
NUDOCS 8106220235
Download: ML20004F727 (5)

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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 Licenses)

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APPLICANTS' RESPONSE TO CFUR's FOURTH

. SET OP REQUESTS FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. $2.741(d). Texas Utilit'.es Generating Company, et al. (" Applicants") he eby submit their response to the requests for production of documents set forth in the " Fourth Set of Interrogatories to Applicant [ sic] and Requests to Produce," served by Citizens for Fa r Utility i

Regulation ("CFUR") on May 13, 1981. Applicants also set forth below the proc edures for insp ection and copying of the documents. requested by CFUR.

APPLICANTS' RESPONSE TO CFUR'S REQUESTS TO PRODUCE CFUR's requests to produce are identified by the item number corresponding to the number in CFUR's Fourth Requests to Produce.

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11.b. Applicants object to this request for production of

. documents for the reasons set forth in their response to Interrogatory 10 in Applicants' June 1, 1981 "An-swers to CFUR's Fourth Set of Interrogatories."

40.b., Applicants object to these requests for production of #

41.b.

documents for the reasons set forth in their response to Interrogatories 39-41 in Applicants' June 1, 1981

" Answers to CFUR's Fourth Set of Interrogatories."

47. Applicants will provide for inspection and copying, pursuant to the procedures set forth below, the fol-lowing documents:

Letter from Westinghcuse Ovners Group to NRC, March 18, 1981, and attachments J (previous submittals to the NRC) .

48. Applicants object to this request for production of documents for the reasons set forth in their response to interrogatory 46 in Applicants' June 1, 1981 "An-swers to CFUR's. Fourth Set of Interrogatories."

PROCEDURES FOR INSPECTION AND COPYING CFUR may inspect and copy the documents identified above according to the following procedures:

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

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

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 expen'se and at a rate of 15 cants per page for photocopying.

Respect u Ay submitted,

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I l Nichol y S '

Reynolds uV s

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

Washington, D.C. 20036 (202)857-9817 1 Counsel for Applicants 4

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- June 17, 1981 O

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-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 (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

CERT-'ICATE OF SERVICE

hereby certiff that copies of the foregoing " Applicants '

Response to CFUR's Fourth Set of Requests for Production 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 17th day of June, 1981:

Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory 1001 Connscticut 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 Cafety and Licensing David J. Preister, Esq.

Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Drotection Commission Division Washington, D.C. 20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711

. Licensing Boara Panel U.S. Nuclear Regulatory Mr. Richard L. Fouke Commission CFUR Washington, D.C. 20555 1568B Carter Drive-Arlington. Texas 76010

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Arch C. McColl, III, Esq. Dwight H. Moore, Es'q. '

701 Commered 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 Mrs. Juanita Ellit Washington, D.C. 20555 President, CASE 1%25 South Polk Street Dallas, Texas 75224 e

William A. Horin t

cc: Homer C. Schmidt Spencer C. Relyea, Esq.

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