ML20010C197
| ML20010C197 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/17/1981 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CITIZENS FOR FAIR UTILITY REGULATION |
| Shared Package | |
| ML20010C198 | List: |
| References | |
| NUDOCS 8108190237 | |
| Download: ML20010C197 (3) | |
Text
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08/17/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!{41SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING COMPANY, ET AL.
)
Docket Nos. 50-445
)
50-446 (Comanche Peak Steam Electric Station.
)
Units 1 and 2)
)
NRC STAFF'S THIRD SET OF INTERR0GATORIES T0, AND REQUEST FOR DOCMENTS FROM, INTERVENOR CFUR The NRC Staff (" Staff") hereby requests that Intervenor CFUR, pur-suant to 10 CFR 95 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying, all documentary mdterial identified in the responses to interrogatories below.
As pro-vided in the " Scheduling Order" issued by the Atomic Safety and Licensing Board (" Licensing Board") on July 23, 1981, these interrogatories relate to information in the Staff's Draft Environmental Statement (DES) which is relevant to allowed contentions.
Pursuant to the Licensing Board's Scheduling Order, these interrogatories must be answered by Sentember 11, 1981.
All references provided in response to these interrogatories are to be identified by author, title, date of publication and publisher if the reference is published; if any such reference is not published, it is to be identified by author, title, date it was written, the qualifications
[ k N O!
2-of the author relevant to this proceeding, and the location where a copy of the document ray be obtained.
All persons named in response to these interrogatories are to be identi-fied by name, address, employer, position, education, professional qualifica-tions, and publications related to their views concerning the subject matter of this proceeding.
INTERROGATORIES ON CONTENTION 9 9-18.A/
S,a?.e whether CFUR contends that the Staff's DES (96 5.8.1 and 5.8.2) fails to adequately resolve the issue (s) raised by CFUR in Contention 9.
9-19.
If the answer to Interrogatory 9-18 is affirmative, state in detail the reasons and basis for CFUR's contention.
9-20.
If the answer to Interrogatory 9-18 is affirmative, identify all persons upon whom CFUR relies in support of this contention along with a summary of their views or positicns relevant to the subject matter of your contention.
3/ Since the first and second sets of interrogatories filed by the Staff on January 19, 1981 and April 10, 1981, respectively, covered Contention 9, the numbering of the interrogatories in this third set will begin where the second set of interrogatories ended.
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. 9-21.
If the answer to Interrogatory 9-18 is affirmative, iden-tify all persons whom CFUR intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
9-22.
If the answer to Interrogatory 9-18 is affirmative, iden-tify all documentary or other material that CFUR intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
Respectfully submitted, th Q k ilc%ch:Id Marjorie Ulman Rothschild Counsel for NRC Staff Dated at Bethesda, Maryland this 17th day of August,1981
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