ML20030C475

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Forwards Supplementary Answer to Interrogatory G-4(c, & Answers to NRC Third Set of Interrogatories & Request for Production of Documents.Related Correspondence
ML20030C475
Person / Time
Site: Comanche Peak  
Issue date: 08/20/1981
From: Ellis J
Citizens Association for Sound Energy
To: Schmidt H
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20030C476 List:
References
NUDOCS 8108260147
Download: ML20030C475 (1)


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Dear Hcuer:

b Sti rating License Proceedings for Comanche Peak Nuclear Plant, Units 1 and 2 Docket Nos. 50-445 aci 50-4h6 I tried to get in touch with you and Nick Reynolds today, but was unable to make contact.

I wanted to inquire if it would be helpfd for us to send you copies of the following items; since I couldn't get in touch, I decided to go ahead and send them at the same time I mail our 8/21/81 Answers to Staf'f's Third Set:

CASE's 8/18/81 Supplementary Answers:

(1).To Applicants Regarding Contention 22; (2).to NRC Staff regarding Contention 22; and (3) to NRC Staff in Response to Staff's 3/4/81 Motion to Compel Responsive Answers to Certain Staff Interrogatories to Intervenor CASE of January 19, 1981 (Staff's First Set to CASE); and CASE's 8/21/81 Answers to NRC Staff Regarding: (1) Supplementary Answers to G-4(c) Inadvertently Omitted from CASE's 8/18/81 Supplementary Answers; and (2) Answers to NRC Staff's Third Set-of Interrogatories to, and Request for Documents from., Inte'rvenor CASE These two pleadings are enclosed.

(Our 8/21/81 Answers to Staff will probably be of limited interest to you, but item (1) may be helpful.)

As we discussed Tuesday when you called, after you've had the opportunity to review our 3/17/81 Motion to Co=pel Applicants re: our Fourth Set of Interroga-tories to Applicants, if you're not sure what we want in the way of answers, please get' in 'toi.ich.' This se' ems to be the only motion pending between CASE and Applicants at this time.

I realize you're interested in getting further information from us as soon as possible about CASE's witnesses, etc., but as indicated in the attached, we're not sure right now about the availability of such witnesses under -thir., expedited hearing schedule. We're in the process of determining which witnesses we want to use and contacting them about their availability, and we'll let you know and

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will supplement our answers just as soon as we have this information ourselves.

8108260147 810820 pfpp PDR ADOCK 05000445 Sincerely, i

O NI g,tr#N&+w E r.nc.tosures s.) Juanita Ellis, President

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