ML19209B115

Response to Houston Lighting & Power Motion to Compel Answers by Intervenors Tx Pirg,Mccorkle & Hinderstein to Util Interrogatories.Tx Pirg Is Making Diligent Effort to Answer;Responses Should Be Ready Shortly

ML19209B115
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	08/10/1979
From:	Clay Johnson TEXAS PUBLIC INTEREST RESEARCH GROUP
To:
References
NUDOCS 7910090190
Download: ML19209B115 (1)

Text

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NRC PUBLIC DOCUMD.T E00M In tL. ;4atter of hp Q'[(  %

IlOUJTON iIC!iTI:.C nD POn"t . CU

( Allcra C ec .:k , Unit 1) 7 f] T.

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g \'\ eg*.Q TexPIRG RLSPONSLS TO I: lap i10 TION TO COi!PEL 6 y

To the !!onorable Board: '

%i td TexPIRG is in receipt of a tiotion by Applicant to ccmpel responses to interrogatories by Intervenors: Te:I'I.;G, ?:c Jork1c , and !!inderstein.

For TexPIRG 3s part, TexPR O rould infcrr: the Doard that Intervenor int end:s to recpend to the interrog.; tories in question as quickly as p o t;.d. ale , and certaialy envisicca .. ahing s.ach responsus by tho' ten' day-frcr:-pror.csed Order data crated oy !!LEP 's ration.

!!ouever, so that the nearci is aware of T2.WIhG's good f4.t.th efforts to nahe such information availabic, TexPL.G will cicarly state the ,

reason for the tr.rdinces. . . .

!!any of !!L&P s interrogatorics were 8

follow-ups to the Appa.icant's deposition of TexPInG witncos Andrew Sanscm. So, these interrogatories

1. s rc provided to 'Ir. Sansam, who is not an e r.ployee of TexPJ.RG, for his analysis. On the proximato date the recpannes were dbe,IIr. Sansac 3 s home in - Brazoria County uas flooded by rain from a tropical stormj and for many days telephone contact could not be made with him. 14r.

Sane m now informs us that he was, by nece;r;/.xy, involved in the repair of damage to his hom.2 during the pact weeks., 2*nw that this unfortunate event has passed, TexPIRC anticipates the rea. oases will be readily fo rthcocint;,. TenPInG requcM.c the cocrd's unJ.crctanding in this matter, and states for t!'c record thnt the or:;anizati.'n has adde a diligent and Cood faith effort to =cet its c uties in the apt,ropriate time periarla, and will continue to do so in the future.

Respectfully / / Clarence Johnson, Laec. Dir.

cc: all parties 1/ Ihe weather bureau recorts that tw .;raas of lirazoria County received 25 inchas of rain in 24 hotu s-au. pcaed..y a once >in- 500 year flood.

!4r. S ansa.s, ca .af yet, ..ca not had mice;,rical s.arvice restored by

!! LAP, .und incideably reporta that swah Jailure has made typing diffi-cult cn hic alactric typevri a.-

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