ML19211C612
| ML19211C612 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/07/1980 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8001140052 | |
| Download: ML19211C612 (3) | |
Text
01/07/80 e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
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HOUSTON LIGHTING AND POWER COMPANY, )
Docket Nos. 50-498 E AL.
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50-499
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(South Texas Project, Units 1 and 2))
NRC STAFF MOTION FOR ORDER COMPELLING CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. TO RESPOND TO STAFi INTERROCATORIES On November 5, 1979, the NRC Staff filed a series of interrogatories directed to the Citizens Concerned About Nuclear Power, Inc. (CCANP). On December 26, 1979 CCANP filed " Answers of Citizens Concerned About Nuclear Power, Inc. to the First Set of Interrogatories and to NRC Staff Interrogatories and Request For Documents" (hereinafter referred to as " Response").
In this Response CCANP indicated that both the Applicants and the Staff's inter-rogatories requested the same information.
Based on that observation, CCANP responced only to the Applicants' interrogatories, leaving for the Staff the task of parsing from these answers information responsive to its own interroga-tories.1/
The NRC Staff finds this approach unacceptable. Section 2.740b(b) of the Commission's Rules of Practice provides that "[e]ach interrogatory shall be answered separate 1*/ and fully in writing...." This has not been done here with respect to the Staff's interrogatories.
Furthermore, the present approach in which CCANP has provided answers only to Applicants' interrogatories without.
1_/
Response, at 1.
CCANP proffers to respond directly to the Staff's inter-rogatories should the Staff find the approach taken unacceptable.
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1743 333 80011 o 0 5 2 g
indicating which Staff interrogatory is responded to does not permit the Staff to determine whether or not CCANP's answers are fully responsive to the Staff's interrogatories.
Therefore, the Staff respectfully requests, pursuant to 10 CFR 8 2.740(f), that the Licensing Board issue an order compelling CCANP to provide :
promptly, in writing under oath, full, direct and responsive answers to each of the Staff's interrogatories filed on November 5, 1979.
Respectfully submitted, C if *.'y, t f.?'74/ W %
Henry J. McGurren Counsel for NRC Staff Dated at Bethesda, Maryland this 7th day of January, 1980 1743 334
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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HOJSTON LIGHTING AND POWER COMPANY, )
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50-499
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=
(South Texas Project, Units 1 and 2 )
CERTIFICATE OF SERVICE I hereby certify th't copies of "NRC STAFF MOTION FOR ORDER COMPELLING CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. TO RESPOND TO STAFF INTERROCATOIRES" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 7th day of January, 1980:
Charles Bechhoefer, Esq., Chairman
- xichard W.
Lowerre, Esq.
Atomic Safety and Licensing Board Assistant Attorney General Panel Environmental Protection Division U.S. Nuclear Regulatory Commission P. O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Dr. James C. Lamb, III Jack R. Newman, Esq.
313 Woodhaven Road Lowenstein, Newman, Reis, Chapel Hill, NC 27514 Axelrad & Toll 1025 Connecticut Avenue, N.W.
Dr. Emmeth A. Luebke*
Washington, DC 20036 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel
- Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Melbert Schwarz, Jr., Esq.
Baker and Botta Atomic Safety and Licensing Appeal One Shell Plaza Panel (5)*
houston, TX 77002 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Lanny Alan Sinkin Citizens Concerned About Nuclear Docketing and Service Section (5)*
Power Office of the Secretary 838 E. Magnolia U.S. Nuclear Regulatory Commission San Antonio, TX 78212 Washington, DC 20555 Mrs. Peggy Buchorn Executive Director Citizens for Equitable Utilities, Inc.
Route 1, Box 432
)[f}}; Brazoria, TX 77422 r-ff7)!fj^"" H4nry J./pcGurren Counseld or NRC Staff}}