ML20148L178

Updates Status of Lehigh Portland Cement Co'S Responses to NRC Staff'S Interrogs & Request for Production of Documents. Interrogs M1-M4,L1-L11 & 01-011 Have Been Answered & Proposed Answers to H1-H11 Have Been Submitted to Bd

ML20148L178
Person / Time
Site:	Green County
Issue date:	10/31/1978
From:	White A DEGRAFF, FOY, CONWAY & HOLT-HARRIS
To:	Goodhope A Atomic Safety and Licensing Board Panel
References
NUDOCS 7811200150
Download: ML20148L178 (2)

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Andrew C. Goodhope, Chairman l l Atomic. Safety and Licensing Board g 4-i 3320 Estelle Terrace Wheaton, Maryland 20906 (f- 7\ py C d h ,h* h $

Re: NRC Docket No. 50-549 Power Authority of the State of New York g M

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- (Greene County Nuclear Power Plant) co -4

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Dear Chairman Goodhope:

This letter will update the status of Lehigh Portland Cement Company's responses to the NRC Staff's interrogatories and request for production of documents. NRC Staff interrogatories to Lehigh Portland Cement Company M1 through M4, L1 through L11, and 01 through 011 have been answered by Lehigh Portland Cement Company with copies of the answers transmitted to all. parties to these pro-ceedings. Proposed answers to interrogatories H1 through H11 have been prepared in consultation with a member of Heidelberg's Manage-ment Board and submitted to the full Board in Heidelberg, Germany.

As of this date, I have not received the answers signed by an appro-priate member of the Heidelberg Management Board. Immediately upon receipt of these answers we will furnish them to the parties as we did with the previous interrogatories.

NRC Staff interrogatories and request for production of docu-ments from Lehigh Portland Cement Company dated September 8, 1978 present substantial questions'of proprietariness and confidentiality.

Lehigh Portland Cement Company will not produce this document for examination by any party to this proceeding. Lehigh stands by its statement that this study concerns locating "a new cement plant in a new part of the country" and does not relate in any way to the

. existence, either present or future, of.Lehigh's-facilities at

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. 5-4:

Andrew C. Goodhope, Chairman October 31, 1978 Page 2

'Cementon. 'Lehigh's reasons for the confidentiality of this study are further detailed in the motion which we expect to make to you later this week under 10 CFR 2.740. In connection with the con-fidentiality of the study which is requested by the NRC Staff, we will furnish a supporting affidavit of Mr. Cummings, who made the statements referred to by Staff in its September 8 interrogatory.

I urge you not to rule on Staff's motion until such time as you have received Lehigh's motion and had an opportunity to rule on l it. l l

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Very truly yours, DeGRAFF, F0Y, CONWAY & HOLT-HARRIS

< 1 Alg:. d F. White, Jr.

AFW:kar cc: All parties 1

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