ML20010H836

Supplemental Response to Citizens Association for Sound Energy Fourth Set of Interrogatories.Affidavit & Certificate of Svc Encl

ML20010H836
Person / Time
Site:	Comanche Peak
Issue date:	09/25/1981
From:	Horin W, Reynolds N, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
NUDOCS 8109290337
Download: ML20010H836 (7)

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September 25, 1981 WK UNITED STATES OF AMERICA c) <.

NUCLEAR REGULATORY COMMISSION ,

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In the Matter of ) p ,(gF

) b .1 TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for 4 .'lf_

Operating License))$

Station, Units 1 and 2) )

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r APPLICANTS' SUPPLEMENTAL REF?ONSE k kk 9 v G'/

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TO CASE'S FOURTH SET OF INTERROGATORIES f

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As indicated in the joint report to the Board concern-irg the September 9, 1981 meeting between Applicants and CASE, the Applicants agreed to provide written responses as a fol'ow-up to the responses to CASE's Fourth Set of Interrogatories discussed in the meeting. In accordance with that agreement, Applicants hereby provide the following information.

I. Contention 22 It was agreed during the meeting that Applicants would reference the appropriate FSAR section in response to Interrog-atory 12; the meaning of emergency planning is discussed in Sec-tion 13.3.

As discussed in the meeting, the Applicants state that their response to Interrogatory 13 is in the affirmative.

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n It was discussed in the meeting and the Applicants hereby affirm the response to Interrogatory 14 is, as follows:

It is the Applicants' position that the Comanche Peak Emer-gency Plan will, by meeting the requirements of 10 C.F.R. Part 50, Appen' dix E, include everything necessary to meat items a.

thru f. referenced in Contention i? with the following excep-tion. There will be no provision for emergency planning for that portion of the Dallas / Fort Worth Metroplex which is out-side the Plume Exposure Emergency Planning Zone, as defined by 10 C.F.R. Part 50, Appendix E.

II. Contention 25 As discussed in the mseting the Applicants amend their responses to Interrogatories 1 thru 11 as follows:

1. Yes.

2.(a) 1. Application for Operating License, April 21,-1978 ii. 1977 Annual Reports of TUGCO, DP&L, TP&L and TESCO; by letter dated August 7, 1978.

iii. 1978 Annual Reports of TUGCO, DP&L, TP&L and TESCO; by letter dated December 4, 1979.

iv. Answers to NRC Finar ,ial Questions; by letter dated April 13, 1981.

(b) The above listed documents were made at silable for inspection and copying as indicated in Applicants' Response to CASE's Request for Production of Docu-ments, dated March 24, 1981.

(c) Yes.

3. At the September 9, 1981 meeting with Applicants, CASE's representatives stated that the terms " timely", " reasonable,"

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" good," and " flexible" are used in the broadest sense. With this understanding, Applicants' answer to Interrogatory No. 3 is "Yes"; hewever, to avoid misunderstand-ing, Applicants would remind CASE that all of the common stock of TESCO and TP&L and all but a small fraction of the common stock of DP&L is owned by Texas Utilities Company, and that BEPC, TMPA and TEX-LA have no investors.

4. Not applicable.

S. Applicants will rely on the documents furnished in response to Interrogatory No. 2 to prove their answers to Inter-rogatory No. 3. In addition, Applicants will submit prefiled testimony relating to their financial qualifications to

operate dhe plant.

6. Not applicable.

7. Not applicable.

8. Not applicable.

9. No.

10. Not applicable.

11. Not applicable.

III. Uranium Supply An item not related to CASE's fourth set of interrog-atories, but which was discussed r. the September 9, 1981 meet-ing, was an apparent discrepancy between a Texas Utilities Com-pany prospectus and a TMPA bond prospectus, dated July 31, 1980, with respect to uranium fuel contracts. In September 1980 a major uranium supply contract was amended. This resulted in a firm supply commitment for 17 years of operation fc each unit, including material to meet the previously unfilled require-ments for the initial core and first reload for Unit #2. Due

to the timing of the TMPA prospectus (July 31, 1980) and the most recent Texas Utilities Company prospectus (March 1981) the nuclear fuel supply situation was, in fact, different at their respective filing dates.

Respec f ly bmitted, Nichod (sf. Reynolds V

d L 0. W William A. Horin' DEBEVOISE & LIBERMAN 1200 Seventeenth St., N.W.

Washington, D.C. 20036 (202)857-9817 Counsel for Applicants September 25, 1981

STATE OF TEXAS )

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COUNTY OF DALLAS )

Homer C. Schmidt, being duly swarn, deposes and says:

That he is Manager, Nuclear Services, Texas Utilities Services, Inc., and knows 'he contents of the foregoing Applicants' Supplemental Response to CASE's Fourth Set of Interrogatories; that the same is true of his owri knowledge excel t as to matters therein stated on information and belief, and as to that, he believes them to be true.

? i SWORN to and subscribed before me on this 21st day of September, 1981 W i e Notary Public b /

My Commission Expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD )

l 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)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Supplemental Response to CASE's Fourth Set of Interrogatories," in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 25th day of September, 1981:

Marshall E. .".ller, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20355 Washington, D.C. 20555 Marjorie Ulman Rothschild, Esq.

Dr. Kenneth A. McCollom Office of the Executive Dean, Division of Engineering, Legal Director Architecture and Technology U.S. Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C. 20555 Dr. Richard Cole, Member David J. Preister, Esq.

Atomic Safety and Licensing Assistant Attorney. General Board Environmental Protection U.S . Nuclear Regulatory Division Commission P.O. Box 12548 Washington, D.C. 20555 Capitol Station Austin, Texas 78711 Chairman, Atomic Safety and Licensing Board Panel Betty B. Brink U.S. Nuclear Regulatory CFUR Commission 7600 Anglin Drive Washington, D.C. 20555 Fort Worth, Texas 76119

. . s Arch C. McColl, III, Esq. Mr. Chase R. Stephens 701 Commerce Street Docketing & Service Branch Suite 302 U.S. Nuclear Regulatory Dallas, Texas 75202 Commission Washington, D.C. 20555 Jef fery L. Hart, Esq.

4021 Prescott Avenue Dallas, Texas 75219 Mrs. Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 4

P William A. Horin ki~

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

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