ML19208D113
ML19208D113 | |
Person / Time | |
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Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
Issue date: | 08/01/1979 |
From: | Degregori G AFFILIATION NOT ASSIGNED |
To: | Biddle, Copeland, Thrash BAKER & BOTTS |
References | |
NUDOCS 7909280003 | |
Download: ML19208D113 (1) | |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20058M0361993-04-12012 April 1993
[Table view]Partial Response to FOIA Request for Documents.Forwards Records in App L Which Are Being Withheld Partially for Listed Reasons,(Ref FOIA Exemptions 5) ML20235B4531987-09-22022 September 1987 Final Response to FOIA Request for Documents Re Specified Dockets.Documents in App a Already Available in Pdr.Forwards App B Documents.App B Documents Also Available in Pdr. Documents for Listed Dockets Could Not Be Located ML20235B3621987-08-25025 August 1987 FOIA Request for Listed Documents for Specified Dockets ST-HL-AE-1666, Requests Relief from Preservice Insp of Certain Component Supports Per Section XI of ASME Boiler Pressure Vessel Code. Attachment 1 Shows Thermal Expansion Testing of Sys Subj to Preservice Exam of Component Supports1986-05-22022 May 1986 Requests Relief from Preservice Insp of Certain Component Supports Per Section XI of ASME Boiler Pressure Vessel Code. Attachment 1 Shows Thermal Expansion Testing of Sys Subj to Preservice Exam of Component Supports ML20140F3691986-01-14014 January 1986 Further Response to FOIA Request for Several Categories of Documents Re Pressure Suppression Containment.Fsar & SER for Limerick Only Documentation Re 4x4 Tests.Encl Apps D-G Documents Responsive to Item 4 Also Available in PDR ML20063H0331982-08-27027 August 1982 Advises That Plants Have Been Canceled.Alternative Dispositions of Application to Be Discussed W/Nrc. Certificate of Svc Encl ML20062G8131982-08-11011 August 1982 Forwards NRC to Util Re Slippage of CP Issuance Date,For Distribution to Parties ML20054H7481982-06-19019 June 1982 Forwards Houston Chronicle 820617 Article Re Util Requested Rate Increase.Article Appears Relevant to Ultimate Fate of Plant & Appears to Represent Slight Change from Util Dec 1981 Position on Plant Destiny ML20054H7581982-06-18018 June 1982 Advises That Feasibility of Continuing Plant Const Remains Under Util Consideration,W/Ultimate Determination Depending on Disposition of Request for Rate Relief Pending Before Tx Public Utils Commission ML20053B8551982-05-27027 May 1982 Advises That If ASLB Decides Evidence on ASLB Questions 1 & 3 Necessary at June 1982 Hearing,Nrc Would Adopt as NRC Testimony,Affidavits Submitted Supporting NRC 820507 Answers ML20052F2301982-05-0505 May 1982 Requests ASLB Consider 820429 Findings of Fact Even Though Findings Late.Due Date Misconstrued.Striking Findings Would Be Significant Penalty for Minor Infraction ML20050J0231982-04-0606 April 1982 Forwards Applicant Answers to Doherty Second & Third Sets of Interrogatories,Questions 29 & 8,respectively,re Quadrex Rept.Related Correspondence ML20050H2341982-04-0606 April 1982 Admits Truth of Items 160-163 in 820323 Request for Admissions.Relevance Not Admitted.Related Correspondence ML20050E4131982-04-0505 April 1982 Advises of Typographical Error in Applicant Answers & Objections to Doherty Fifth Set of Interrogatories.Related Correspondence ML20050E2851982-04-0505 April 1982 Forwards Applicant Answers & Objections to J Doherty Sixth & Seventh Sets of Interrogatories Re Quadrex Rept.Related Correspondence ML20050C7771982-03-31031 March 1982 Forwards IE Bulletin 82-01, Alteration of Radiographs of Welds in Piping Subassemblies. No Specific Actions Required ML20050C4991982-03-26026 March 1982 Forwards Jh Goldberg Testimony on Technical Qualifications, Lj Sas Testimony on Tx Pirg Addl Contention 31 & Applicant Response to Jf Doherty Request for Documents.Related Correspondence ML20042C6231982-03-25025 March 1982 Explains Problems W/Timing of Filings & Tx Bar Exam ML20042B5051982-03-16016 March 1982 Forwards Bechtel Preliminary Assessment Rept on Quadrex Rept.J Doherty Also Being Served Which Renders 820305 Motion for Bechtel Quadrex Rept Review Moot.W/O Encl. Related Correspondence ML20049J6861982-03-15015 March 1982 Advises That Future of Facility Still Under Review.Aslb Timely Decision Is Important Factor in Evaluation. Certificate of Svc Encl ML20049J6701982-03-10010 March 1982 Forwards Table of Contents & Citations Inadvertently Omitted from Applicant 820305 Brief in Opposition to Appeal of R Alexander ML20041F0881982-03-0909 March 1982 Forwards Attachment 1 to Applicant Answers to Doherty First Set at Interrogatories Re Quadrex Rept ML20041D8591982-03-0202 March 1982 Comments on Generic Ltr 81-40 Re Qualifications of Reactor Operators - License Exams ML20041B0671982-02-18018 February 1982 Responds to NRC Re Application of Final Rule on Licensing Requirements for Pending CP & Mfg License Applications.Final Rule Did Not Identify Need for Clarifying Changes to Facility Application.Commitments Acceptable ML20040H3381982-02-12012 February 1982 Forwards Util 820212 News Release Re Feasibility of Plant Licensing & Const,Per 820209 Conversation ML20040F8111982-02-0505 February 1982 Responds to Sj Wolfe .Ser Suppl 3 Needs to Be Supplemented or Altered Due to Commission Final Rule Re Licensing Requirements for Pending CPs ML20039E9771982-01-0808 January 1982 Forwards NRC Proposed Findings of Fact & Conclusions of Law on Environ Matters.Exhibit & Witness Index to Be Provided W/Applicant Safety Findings ML19255A1721982-01-0606 January 1982 Requests Temporary Waiver to 10CFR73.21 (d)(2) Re Storage of Unclassified Safeguards Info.Gsa Approved Containers Have Been Requisitioned W/Earliest Possible Delivery Date of 820315 ML20062M6221981-12-11011 December 1981 Requests Citizens for Fair Util Regulation Respond to Applicant Interrogatories 45-3 Through 83-3,subj of ASLB 810728 Order.Response Necessary So Applicant Can Seek Addl Discovery on Contention 4.Related Correspondence ML20033D0111981-12-0303 December 1981 Advises That Long & short-term Interest Rates in Table 20.2 of Peterson Written Testimony Are Both Actual Cost to Company & Stated or Face Amount of Interest Rate ML20033C9461981-12-0101 December 1981 Forwards Order of Witness Presentation.Names of Corps of Engineers Witness & NRC Witness on Generic Issues to Be Furnished Later in Wk.Svc List Encl.Related Correspondence ML20033A4221981-11-23023 November 1981 Forwards Transcript of 811116 Hearing,Pp 19,866-19,876, Wherein ASLB Ruled on Util & NRC 811030 Joint Motion to Establish Schedule to File Proposed Findings of Fact & Conclusions of Law & on J Doherty 811106 Motion to Reply ML20032C6691981-11-0606 November 1981 Forwards M Field Memo Explaining Correction to Testimony Re Tx Pirg Contention 6 on Mannings Coefficient.W/O Encl ML20032D9101981-11-0606 November 1981 Forwards Proposed Schedule for Presentation of Witness for 811116-20 & 1207-11 Hearing Sessions,Per ASLB 811030 Hearing Recommendation.Related Correspondence ML20032B1991981-10-30030 October 1981 Forwards Testimony of Vth Leung Re Doherty Contention 11,WL Brocks Re Doherty Contentions 15,21 & 24 & Je Knight & Je Kennedy Re ASLB Questions on Scram Discharge Level Monitoring Sys ML20032C8991981-10-29029 October 1981 Forwards Responding to ACRS Re post- Accident Inerting Sys ML20032C2761981-10-28028 October 1981 Responds to 810915 Request Re ATWS Issue.Util Committed Not to Preclude Incorporation of Any Design Mods Included in NUREG-0460,Vol 4 & to Incorporate Eventual Resolution of ATWS Issue in Design.Related Correspondence ML20011A6271981-10-22022 October 1981 Forwards F Litton Testimony Re Doherty Contention 43 on Stainless Steel Cleaning & Reg Guide 1.54.Testimony Should Be Presented on 811029 to Conserve Travel Funds & to Keep Continuity of Scheduled Issues Intact ML20031G9041981-10-16016 October 1981 Forward Applicant & NRC Agreed Order of Witness Presentation for 811116-20 Evidentiary Hearings.Related Correspondence ML20031E5441981-10-14014 October 1981 Forwards Table 1 & Attachment 1 to Rl Gotchy 811009 Testimony Re Increased Risk of Cancer & Noncancerous Effects of App I Levels of Radiation & T Urbanik Testimony Re Facility Evacuation Time Estimate Study ML20032B1271981-10-0808 October 1981 Forwards ACRS Re post-accident Inerting Sys ML20031F2921981-10-0808 October 1981 Clarifies 810817 Memo Re Status of State & Local Emergency Preparedness.State of Tx Has Not Prepared site-specific Plans.Any Unusual Problems Will Be Adequately Handled as site-specific Emergency Plans Are Developed ML20040A8681981-10-0404 October 1981 FOIA Request for NRC Reply to Senator L Bentsen Re Status of Facilities ML20031C4461981-10-0101 October 1981 Submits Applicant & NRC Schedule of Witness for 811005-09 & 26-30 Evidentiary Hearing Sessions ML20010H4131981-09-18018 September 1981 Forwards CM Ferrell & L Soffer Testimony Re Bishop Contention 1,MW Hodges Testimony Re Doherty Contention 38B & Rl Tedesco to Util Requesting Addl Info Re ATWS Issue ML20031H3181981-09-18018 September 1981 Forwards Util Supplemental Affidavit & Testimony on Contentions Still in Issue.Related Correspondence ML20031A9591981-09-16016 September 1981 Discusses Presentation at 257th ACRS Meeting on 810910-12 Re post-accident Inerting Sys Proposed as Means of Combustible Gas Control for Facilities.Acrs Requests Design Review Before NRC Approval ML20010H4291981-09-15015 September 1981 Requests Util Update FSAR for Review Prior to NRC Update of SER Section 15.2 & App C ML20010E6381981-09-0303 September 1981 Responds to ASLB Request for Parties Views on Status of Rn-222 Question.Present Record on Radon Sufficient to Support NRC Conclusion That Dose Commitments & Health Effects of U Fuel Cycle Are Insignificant ML20010E5921981-09-0202 September 1981 Forwards NRC & Applicant Order of Witness Presentation for 810914-18 & 1005-16 Hearings,Per ASLB 810616 Order as Modified 1993-04-12 Category:EXTERNAL CORRESPONDENCE MONTHYEARML19341D6601981-03-30030 March 1981
[Table view]Confirms 810409 Appearance for Deposition in Ofcs of Baker & Botts.All Workpapers Re Testimony Should Be Brought.Related Correspondence ML20003C5971981-02-24024 February 1981 Forwards Schedule for Health & Safety Portion of Facility Licensing Proceedings Presented on 810223.Certificate of Svc Encl ML19347C6671980-12-27027 December 1980 Expresses Concern Re Amount of Time Taken to Handle & Process Requests Re Reed Rept ML19343A7881980-11-17017 November 1980 Advises That Applicant Has Identified NUREG-0594, Occupational Radiation Exposure at Commercial Nuclear Power Reactors 1978, as Document to Be Used in Prepared Testimony Addressing Tx Pirg Addl Contention 21 ML19332B1781980-09-24024 September 1980 Forwards Applicant Response to First Set of Interrogatories. Provides Status of ASLB Actions Re Final Language of Emergency Planning Contention.Applicant Will File Updated Response,If Necessary,Following Review of ASLB Order ML19318D1601980-06-30030 June 1980 Forwards Page 12 to Be Inserted in Applicant Response to Jf Doherty 14th Set of Interrogatories.Related Correspondence ML19323H6621980-06-0606 June 1980 Forwards 800606 Interrogatories & Requests for Production of Documents ML19323D8001980-04-18018 April 1980 Confirms Understanding That WE Rentfro Will Be Leading Party for Discovery,Presentation of Witnesses & cross-examination Re Consolidated Contention Pertaining to High Voltage Transmission Lines' Health Effects.Certificate of Svc Encl ML19323E5381980-04-15015 April 1980 Advises That Jm Bishop Contention 23(c) & P Hinderstein Contention 5 Have Been Consolidated.C Hinderstein Will Conduct Discovery & Pleadings Re Consolidated Contention. Requests That Jm Bishop Be Provided W/Copies ML19323J1771980-03-31031 March 1980 Responds to Telcon & Ltr Requesting Clarification of Applicant Responses to 13th Set of Interrogatories.Explains Use of Citations & Extent of Answers.Related Correspondence ML20126C1291980-03-19019 March 1980 Advises That Proposed Barge off-loading Facility in Brazoria County Will Not Affect Sites on Natl Register of Historic Places,Based on Review of Archeological Evaluation ML19309C1551980-02-0707 February 1980 Requests That Public Utils Board Provide Full & Complete Answers to Incomplete Interrogatories ML19294B7981980-02-0505 February 1980 Notifies of Receipt of Tx Pirg Answers to Util Fourth Set of Interrogatories.Requests Identification of Individuals Providing Technical Knowledge for Specified Intervenor Contention ML19296B8181980-01-29029 January 1980 Forwards Listing of Addl Documents for Possible Citation Re Certain Contentions & Response to Request Re Conservation Elasticities ML19290C5991980-01-0303 January 1980 Forwards Fourth Set of Interrogatories Re Tx Pirg New Contentions Admitted at Fall 1979 Prehearing Conference ML19209C2111979-10-0202 October 1979 Responds to Request Re Effect of Plant Const on Historical Sites.Tx Historical Commission Suggests That Project Implementation May Effect Sweeny Plantation & Other Sites. Forwards List of Profs Who Could Aid NRC ML19208D1131979-08-0101 August 1979 Expresses Opposition to Nuclear Power ML19263A8321978-12-0707 December 1978 Forwards Documents Filed W/Aslb on 781113,including Response to Contentions & Stipulations of Intervenors.W/O Encl ML20235C4151974-05-24024 May 1974 Expresses Concern Re Energy Crisis Proclaimed by Ofc of President & Unreasonable Length of Time Needed to Construct & License Nuclear Power Plants 1981-03-30 Category:EXTERNAL LETTERS ROUTED TO NRC MONTHYEARML19341D6601981-03-30030 March 1981
[Table view]Confirms 810409 Appearance for Deposition in Ofcs of Baker & Botts.All Workpapers Re Testimony Should Be Brought.Related Correspondence ML20003C5971981-02-24024 February 1981 Forwards Schedule for Health & Safety Portion of Facility Licensing Proceedings Presented on 810223.Certificate of Svc Encl ML19347C6671980-12-27027 December 1980 Expresses Concern Re Amount of Time Taken to Handle & Process Requests Re Reed Rept ML19343A7881980-11-17017 November 1980 Advises That Applicant Has Identified NUREG-0594, Occupational Radiation Exposure at Commercial Nuclear Power Reactors 1978, as Document to Be Used in Prepared Testimony Addressing Tx Pirg Addl Contention 21 ML19332B1781980-09-24024 September 1980 Forwards Applicant Response to First Set of Interrogatories. Provides Status of ASLB Actions Re Final Language of Emergency Planning Contention.Applicant Will File Updated Response,If Necessary,Following Review of ASLB Order ML19318D1601980-06-30030 June 1980 Forwards Page 12 to Be Inserted in Applicant Response to Jf Doherty 14th Set of Interrogatories.Related Correspondence ML19323H6621980-06-0606 June 1980 Forwards 800606 Interrogatories & Requests for Production of Documents ML19323D8001980-04-18018 April 1980 Confirms Understanding That WE Rentfro Will Be Leading Party for Discovery,Presentation of Witnesses & cross-examination Re Consolidated Contention Pertaining to High Voltage Transmission Lines' Health Effects.Certificate of Svc Encl ML19323E5381980-04-15015 April 1980 Advises That Jm Bishop Contention 23(c) & P Hinderstein Contention 5 Have Been Consolidated.C Hinderstein Will Conduct Discovery & Pleadings Re Consolidated Contention. Requests That Jm Bishop Be Provided W/Copies ML19323J1771980-03-31031 March 1980 Responds to Telcon & Ltr Requesting Clarification of Applicant Responses to 13th Set of Interrogatories.Explains Use of Citations & Extent of Answers.Related Correspondence ML20126C1291980-03-19019 March 1980 Advises That Proposed Barge off-loading Facility in Brazoria County Will Not Affect Sites on Natl Register of Historic Places,Based on Review of Archeological Evaluation ML19309C1551980-02-0707 February 1980 Requests That Public Utils Board Provide Full & Complete Answers to Incomplete Interrogatories ML19294B7981980-02-0505 February 1980 Notifies of Receipt of Tx Pirg Answers to Util Fourth Set of Interrogatories.Requests Identification of Individuals Providing Technical Knowledge for Specified Intervenor Contention ML19296B8181980-01-29029 January 1980 Forwards Listing of Addl Documents for Possible Citation Re Certain Contentions & Response to Request Re Conservation Elasticities ML19290C5991980-01-0303 January 1980 Forwards Fourth Set of Interrogatories Re Tx Pirg New Contentions Admitted at Fall 1979 Prehearing Conference ML19209C2111979-10-0202 October 1979 Responds to Request Re Effect of Plant Const on Historical Sites.Tx Historical Commission Suggests That Project Implementation May Effect Sweeny Plantation & Other Sites. Forwards List of Profs Who Could Aid NRC ML19208D1131979-08-0101 August 1979 Expresses Opposition to Nuclear Power ML19263A8321978-12-0707 December 1978 Forwards Documents Filed W/Aslb on 781113,including Response to Contentions & Stipulations of Intervenors.W/O Encl ML20235C4151974-05-24024 May 1974 Expresses Concern Re Energy Crisis Proclaimed by Ofc of President & Unreasonable Length of Time Needed to Construct & License Nuclear Power Plants 1981-03-30 |
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Cear Misters Copeland, :.ccle, Thrash, Newman, Culo, lowenstein, Reis, Axelrac, and Toll:
I keep getting huge brown envelopes in the = ail frem Baker & Botts concerning the licencing of the planned Allens Creek nuclear plant, and I a= becc=ing very exasperated by these letters frem Baker & Botts stating that such-and-such a petition to intervene should be denied because the reasons were too " vague." No matter what the reasons are, let's face it, won't you always find them too vague?" For no petition to intervene is 'Gely to satisfy d
you because you are hired by h%D to find something wrong with the petitions.
I tnink that da= age to the healthy functioning of humans or plans is clear when it happens; anybody knows that our organs are made to function a certain way and when something goes wreng, it is clear enough. Anybody knows that humans cecend on plants for their lives, and damage to plant health and function is clear enough when it is dene.
Furthermore, while I as returning to you c:7 opinion on your ocinion, I want to add that I as further exasperated by the language you use to recc==end cenial c2 a petition. It seems that you cannot write a ci=ple statement.
It
=ust be long, full of legal terms, abbreviationi and numbers, all meant to con-fuse anc inti=idate people like us petitioners. You lawyers in your pinstriped threepieced suits are probably secretly laughing at cur efforts.
You =ust have hearts undar those clothes, and I wnder if you have really stopped what yeu're doing, separated your =ics from legal work, and asked yourselves if it is =crally rizht anc in the interest of the health, not ecmfert, of humanity (including those closest to your hearts) to build more and more nuclear plants?
Sincerely, Gayle De Grege _
2327 Goldsmith 49OM06 Heusten, Texas 77030 p.s. I am sending copies of this letter to those en the latest 21st you sent me.
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