ML20062J017

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Forwards Util Response to Interrogatory 3-5,including Tech Specs,Procedures & Requested Documents.Requests That Page 41 of Response to Interrogatory 3-6,submitted 800822,be Corrected to Documents Indicated.Related Correspondence
ML20062J017
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 09/10/1980
From: Gallo J
ISHAM, LINCOLN & BEALE
To: Jordan W
SHELDON, HARMON & WEISS
Shared Package
ML20062J020 List:
References
NUDOCS 8009150339
Download: ML20062J017 (2)


Text

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William S. Jordan, III, Esquire ec Harmon t Weiss

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a, Washington, D.C. 20006 Re:

In the Matter of Consumers Power Company (Big Rock Point Nuclear Power Plant) Occket No. 50-155

Dear Bill:

I am enclosing Consumers Power Company's response to Interrogatory 3-5 together with the documents indicated.

to be enclosed.

This answer completes the Company's response-to your First Set of Interrogatories.

We are working to complete our response to your Second Set ASAP.

b' We have not answered the questions posed in para-graph (g) and the first sentence of paragraph (f).

The first sentence of paragraph -(f) asks for too much.

A detailed f

description of the manufacturing process of each component of the fuel pool liner from the " raw materials to the completed product" seems to me to be oppressive.

Moreover, I fail to see any materiality of the mining and milling processes for the stainless steel and other raw materials needed to fabricate the liner with the issues in this case.

The same sort of comments are generally applicable to paragraph (g).

If I have misinterpreted the meaning of these paragraphs, or if you wish to be more specific, please call and we can discuss matters.

However, I trust that the wealth of information provideu with enis response will satisfy your needs.

l 8009150 3 37

t 3 You requested in the interrogatories that we answer each question in four parts, the third of which was:

C.

Identify and provide all documents and studies, and the particular parts thereof, examined but not relied upon by the Licensee, which pertain to the subject matter in question.

We have interpreted this request as meaning those documents and studies examined by Licensee in preparing responses to these interrogatories.-

This interpretation is consistent with item 3 which requests that the studies and documents relied uport as a. basis for the answer be identified and provided.

Please correct an error in our response to Inter-rogatory 3-6 which was sent to you on August 22, 1980.

Page 41 of that submission states that three documents would be provided ASAP under separate cover.

In fact, these documents were enclosed with the rest of the documents as a part of our response of August 22.

I apologize for any inconvenience.

Please call if you have any questions.

Sincerely, Jose Gallo JG/kar Enclosures 4

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