ML20009B308

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Motion to Modify 810304 Motion to Compel Responsive Answers to NRC 810119 Interrogatories Directed to Citizens Association for Sound Energy.Answers Per 810406 Suppl Addressed Initial Deficiencies.Certificate of Svc Encl
ML20009B308
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/13/1981
From: Rothschild M
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8107150249
Download: ML20009B308 (4)


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o KI UNITED STATES OF AMERICA dhjg NUCLEAR REGULATORY COMMISSION JUL 14 Jgg4hl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD q

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In the Matter of TEXAS UTILITIES GENERATING COMPANY, ET AL.

Docket No.

(Comanche Peak Steam Electric Station, Units 1 and 2)

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NRC STAFF'S MOTION TO MODIFY ITS MARCH 4, 1981 MOTION TO COMPEL AGAINST CASE On March 4,1981, the NRC Staff filed "NRC Staff's Motion to Compel Responsive Answers to Certain Staff Interrogatories to Intervenor CASE of January 19, 1981." For tF? reasons set forth in the Staff's motion, certain of CASE's initial answers to the Staff's interrogatoriesM were inadequate l

responses to those interrogatories. On April 6,1981, CASE filed " Supple-ment to CASE's Answers to NRC Staff's First Set of Interrogatories To, And Request For The Production of Documents From Intervenor CASE."

To assist the Licensing Board in ruling on outstanding motions, the Staff wishes to inform the Licensing Board that based on the Staff's review of the answers in CASE's supplement, the Staff has determined that a number of the answers provided by CASE in its Supplement addressed the deficiencies in CASE's initial answers. Accordingly, the Staff moves to modify its Motion to Compel l

M ee " CASE's Answers to NRC Staff's First Set of Interrogatories and S

Request For The Production of Documents," February 17, 1981.

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8107150249 910713 PDR ADOCK 05000445 G

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- by withdrawing its request for a Licensing Board Order compelling adequato responses, except with respect to the following interrogatories:

1.

General Interrogatories _

G-4(a); G-4(c); G-5.

Interrogatories Related to Specific Contentions _

II.

Contention 22 22-2(c)(i); 22-5(c)(v) through 22-5(c)(xi); 22-6(c)(ii);

22-6(c)(iv); 22-6(vii); 22-6(c)(viii); 22-7(c)(xvi); 22-7(c)

(xvii);22-7(c)(xviii);22-7(c)(xxi);22-7(c)(xxix);22-7(c)

(xxx); 22-7(c)(xxxi); 22-7(c)(xxxiv).

Contention 24 24-4(d); 24-4(e); 24-5(a) through 24-5(j) and 24-5(m) ?.hrough 24-5(r).

Respectfully submitted, L n 0 $ns A 7J ll4 Marjorie Ulman Roths:.nild Counsel for NRC Staff Dated at Bethesda, Maryland this 13th day of July,1981

d UNITED STATES OF ANERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of lEXAS UTILITIES GENERATING COMPANY, ET AL.

Docket Nos. 50-445 50-446 (Couanche Peak Steam Electric Station, Units 1 and 2)

)

CERTIFICATE OF SERVICE l

I hereby certify that copies of "NRC STAFF'S MOTION TO MODIFY ITS MARCH 4, 1981 i

MOTION TO COMPEL AGAINST CASE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indi-cated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 13th day of July, 1981:

Marshall E. Miller, Esq. tnairman*

Dwight H. Moore, Esq.

Aduinistrative Judge West Texas Legal Services atouic Safety and Licensing Board 100 Main Street (Lawyers Bldg.)

U.S. Nuclear Regulatory Commission Fort Worth, TX 76102 Washington, DC 20555 David J. Preister, Esq.

Dr. Forrest J. Remick, Administrative Assistant Attorney General Judge Environmental Protection Division Atomic Safety and Licensing Board P.O. Box 12548, Capital Station l

305 E. Hamilton Avenue Austin, TX 78711 1

State College, PA 16801 Mr. Richard Fouke l

Dr. Richard Cole, Administrative Judge

  • 1668-B Carter Drive l

Atomic Safety and Licensing Board Arlington, TX 76010 U.S. Nuclear Regulatory Commission Washington, DC 20555 Arch C. McColl III, Esq.

701 Commerce Street Nicholas S. Reynolds, Esq.

Suite 302 Debevoise & Liberman Dallas, TX 75202 1200 17th Street, N.W.

Washington, DC 20036 Jeffery L. Hart, Esq.

4021 Prescott Avenue l

Mrs. Juanita Ellis Dallas, TX 75219 President, CASE 1426 South Polk Street Vallas, TX 75224 l

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_2-Atomic Safety and Licensing Board Docketing and Service Section (7)*

Panel

  • Office of the Secretary U.S. Nuclear 'kegulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Panel (5)*

U.S. Nuclear Regulatory Commission Washington, DC 20555 k1u.hn &

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I Marjo/ie Ulman Rothschild Counsel for NRC Staff i

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