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Response in opposition to licensee 800716 motion for sanctions against TMI Alert for failure to answer interrogatories.Burden falls upon licensee to analyze 800506 & 30 responses that are complete.W/Certificate of Svc.

Accession Number: ML19330C125

Date Released: Tuesday, December 10, 2019

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• ML19330C124 - Response in opposition to licensee 800716 motion for sanctions against TMI Alert for failure to answer interrogatories.Burden falls upon licensee to analyze 800506 & 30 responses that are complete.W/Certificate of Svc. (17 page(s), 7/31/1980)
• ML19330C128 - Correction of TMI Alert 800727 motion for revision of Contention 5,that should be dated 800728.Corrected version encl. (1 page(s), 7/31/1980)
• ML19330C130 - Revised Contention 5.Contention was incorrectly dated 800726 & inadvertently cited 10CFR50.40 twice.Certificate of Svc encl. (3 page(s), 7/28/1980)
• ML19330C133 - Revision of Contention 6 alleging that TMI-2 accident has severed & weakened licensee financial position.Intends to submit expert analysis of "TMI Financial Fallout," available to public.Certificate of Svc encl. (3 page(s), 7/31/1980)
• ML19330C134 - Motion to withdraw Contention 7 due to scarcity of financial resources.Draws ASLB attention to serious problems still existing re 10,000 gallon leak that should be addressed in answer to interrogatories.W/Certificate of Svc. (6 page(s), 7/31/1980)