ML19211C672

Fourth Set of Interrogatories & Requests for Production of Documents,Directed to Tx Pirg.Includes Request for Info Re Contention 1 Alleging Existence of Natural Gas Fired Generation as Alternative to Facility.W/Certificate of Svc

ML19211C672
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	12/19/1979
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	TEXAS PUBLIC INTEREST RESEARCH GROUP
References
NUDOCS 8001140156
Download: ML19211C672 (35)

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BEFORE THE ATOMIC SAFETY AND LICENSING BC3RD Yi In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S HOUSTON LIGHTING & POWER COMPANY'S FOURTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO TEX PIRG Pursuant to Section 2.740b and 2.741 of the Commission's Rules of Practice, Houston Lighting & Power Company (Applicant) propounds this Fourth Set of Interrogatories and Requests for Production of Documents to Texas Public Interest Research Group (TexPirg) . Applicant incorporates herewith the instructions and definitions set forth in its First Set of Interrogatories and Request for Production of Documents to TexPirg.

Interrogatories A. With respect to TexPirg's Amended Additional Contention 1 (regarding natural gas fired generation as an alternative to ACNGS) provide the following information:

1. Identify the market, and/or geographic area, where the alleged " glut" of natural gas exists, provide an estimate as to the amount of 1742 222 8001140 /d'($

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natural gas that exists in this market which is not committed to contract, and state the average price per MMBtu of the gas in this market, or if unknown, the estimated cost s

of the gas in this market. (Specify the basis of the estimate).

2. Identify the " improved seismic and holographic techniques" referred to in the contention, and state what would be shown if these techniques were applied at 30,000 feet or more.

3. Identify the location of all natural gas wells within the market area identified in A.l.

which have been drilled to a depth of 30,000 and for each such well specify: (a) the volume of gas produced by the well, (b) the actual price of the gas, or if unknown, the estimated cost of gas (specify the basis for the estimate), (c) whether the gas is presently under contract for sale.

4. As noted at FS-FES page S.9-2, the Federal Power Commission has concluded that the rate of development of natural gas supplied will be inadequate to meet current projections of future natural gas demand. Identify any 1742 223 studies or documents which indicate that this conclusion is in error.

5. Identify any studies or documents which show that a new natural gas fired plant will produce electricity more economically than a nuclear powered steam electric station.

6. Identify the documents which show that

" Applicant has prepared projections of natural gas prices for the future which indicate the price as adjusted for inflation will decline."

7. Identify by title the " numerous analyses of historical data" and the study done by Sandia Laboratories for the NRC Staff regarding the capacity factor for nuclear plants.

8. Based on the " historical data for recent vintage nuclear plants", what is TexPirg's estimate as to the capital cost for ACNGS?

Identify by title any studies or documents from which you derived this " historical data" on capital costs.

9.. Specify how much less physical land space would be required if ACNGS were to be replaced by 1200 MW of natural gas fired generation.

1742 224

10. Produce the documents or studies which TexPirg relies upon to conclude that natural gas generators pose less occupational risk during the fuel extraction process than do other processes.

11. Specify the extent and type of the land damage associated with tl.e fuel extraction processes, and produce the documents relied upon for the comparison.

12. Specify how much less water would be consumed by 1200 MW of generation fueled by natural gas as compared to the water consumption of ACNGS.

Also specify the increase in ambient water temperature resulting from discharges from a natural gas fired plant as compared to ACNGS.

13. Identify the source of the statement that Houston is a "non-attainment area".

14. Define the extent of the Houston air quality "non-attainment area."

15. For what pollutants does TexPirg contend the above area is a "non-attainment area"?

16. State what natural gas air pollutants are

" manageable" and by what method.

1742 225

17. Does TexPirg contend that Applicant is automatically entitled to an exemption under the Industrial Fuel Use Act of 1978 if Houston is a non-attainment area. If so, what is the basis for such an assertion.

18. Describe the work TexPirg has done, whether or not complete, on the economic and environ-mental advantages of natural gas compared to nuclear power. Furnish copies of the documents which reflect this work, whether or not complete.

As used in this question, " work" includes studies you have done, whether or not complete as of the date of your answer to this interrogatory, and documents reflecting discussions with experts and/or prospective witnesses and research.

19. Produce all documents which relate to Interrogatory Nos. Al through A18 hereof.

20. Identify the person who answered Interroga-tory Nos. Al through A18 hereof,

21. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

1742 226

22. (a) Identify each expert witness you intend to call in this proceeding to testify concernir.g this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the_ factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having the technical knowledge in the subject area covered by this contention.

B. With respect to TexPirg Amended Contention 2 (regarding interstate interconnections) , provide the following information:

1. Identify by title the study done by the Subcommittee on Energy of the Joint Committee of Congress, which is referred to in this contention.

I74L2 227

2. Identify any studies which show that it would be economically feasible for Applicant to reduce its reserve margin through " inter-connection of grids".

3. Provide the claculation of the reduction in the HL&P reserve margin available as a result of the specific interconnections specified in response to interrogatory B.3 above.

4. Identify the " grids" referred to in this contention and specify the location, size and total cost for interconnecting these " grids".

5. Identify each utility system which TexPirg asserts has excess capacity available for sale to Applicant anytime after 1987, and for each such utility specify: (a) the amount of capacity available for sale, (b) whether the capacity identified in (a) is available for sale on a firm basis, (c) the cost of the energy available for sale.

6. Identify the amount of additional capacity available from conservation in each of the above specified utility systems, and specify the study or studies used and/or method of calculating the additional capacity.

1742 228

7. Identify by title any studies or documents showing that there will be a reduction in demand for electricity in Applicant's service area as a result of the EPA's designation of the Houston area as an air quality non-attainment area.

8. Describe all the work you have done (whether or not complete) to support your contention regarding: (i) the amount of excess energy available through interconnections; (ii) the extent to which HL&P's reserve margins could be reduced by virtue of interconnections; and (iii) the forecast of reduced industrial electric demand. Furnish copies of the docu-ments which reflect this work, whether or not complete. As used in this question, " work" includes studies you have done, whether or not complete as of the date of your answer to this interrogatory, and documents reflecting discus-sions with experts and/or prospective witnesses and research.

9. Produce all documents in TexPirg's possession which relate to Interrogatory Nos. Bl through B8.

1742 229

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10. Identify the person who answered Interrogatory Nos. B1 through B8 hereof.

11. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

12 (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(el Identify the person or persons having the technical knowledge in the subject, area covered by this contention.

1742 230

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C. With respect to TexPirg's Amended Contention 3 (regarding Applicant's technical qualifications) , provide the following information:

1. Identify by title the Applicant's 1978

" internal study" referred to in paragraph (b) of this contention.

2. Identify (including report numbers) each document relied upon in support of paragraph (c) of this contention.

3. As to paragraph (c) of this contention, specify exactly which portions of the PSAR were deviated from according to the documents identified in C2 above.

4. Identify (including report numbers) each document relied on in support of paragraph (d) of this contention.

5. Identify (including report numbers) each document relied on in support of paragraph (e) of this contention.

6. Identify (including report numbers) each document relied on in support of paragraph (f) of this contention.

7. State whether TexPirg now has knowledge of "what in fact occurred in [the] incident" 1742 231 10-

referred to in paragraph (f) of this contention.

If so, state what that knowledge is and identify the source of that knowledge.

8. Describe each of the 24 items of non-compliance referred to in paragraph (g), and identify (including report numbers) each document relied on in answering this question.

9. Describe each of the " numerous construction problems" referred to in paragraph (g) of this contention and identify (including report numbers) any documents relied on in answering this question.

10. State whether TexPirg contends that Applicant's quality assurance program for ACNGS does not comply with 10 CFR 50, Appendix B, and if so, specify each paragraph of Appendix B with which Applicant has not complied and the reason for the alleged failure to comply with each such paragraph.

11. Identify the persons with whom TexPirg or those acting on its behalf, has spoken in connection with (i) framing this contention; and (ii) presenting testimony or other evidence on the subject matter of this contention.

1742 232

12. Produce all documents in TexPirg's possession which relate to Interrogatory Nos. Cl through C1.

13. Identify the person who answered Interrogatory Nos. Cl through Cll.

14. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

15. (a) Identify each expert witness you intend to call in thiF proceeding to testify Concerning this contention.

(b) State the qualifications and credentials of each such expert wintess.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(el Identify the person or persons having the technical knowledge in the subject area covered by this contention.

1742 233 D. With respect to TexPirg's Additional Contention 15 (regarding radiation exposure to workers), provide the following information:

1. Referring to page S.5-29 of the FS-FES, the Staff estimates that on the basis of past exposure experience from operating plants, occupational radiation dose at ACNGS will be 500 man-rems per year. State whether TexPirg contends that this estimate is in error, and if so, specify the number of man-rems per year which TexPirg contends the Staff should have used in its analysis and provide the source of this estimate.

2. Referring to page S.5-29 of the FS-FES, the Staff " determined that the applicant is committed to design features and operating practices that will assure that individual

. occupational radiation doses can be maintained within the limits of 10 CFR Part 20 and that individual and total plant population doses will be as low as is reasonably achievable."

State whether TexPirg disagrees with this conclusion, and if so, specify which portions of the conclusion are in error, with an explanation as to why it is in error.

1742 234

3. Is it TexPirg's contention that, with respect to occupational exposures, ACNGS will not comply with applicable regulatory requirements.

Specify each requirement which will not be met and the basis for each assertion of non-compliance.

Provide any supporting analyses which has been performed by TexPirg on this contention. .

4. Produce all documents in TexPirg's possession which relate to Interrogatory Nos. D1 through D3.

5. Identify the person who answered Interrogatory Nos. D1 through D4.

6. Identify any non-expert witness TexPirg intends to have testify on this contention, and pr; vide a summary of each such witness' testimony.

7. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

I742 235 (d) State the f actual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having the technical knowledge in the subject area covered by this contention.

E. With respect to TexPirg's Additional Contention 22 (regarding control room design) , provide the following information:

1. Specify every reason why the control room design for ACNGS is not sufficient to insure that the plant operators can safely control the plant under all accident conditions.

2. Identify the specific instrumentation at ACNGS which TexPirg alleges is not " sufficient" to insure that the operators can safely control the plant under all accident conditions."

Identify specifically the accident conditions for which the instrumentation is insufficient.

Identify the deficiency in each instrument alleged to be insufficient.

1742 236

3. In preparing this contention and in your preparations for litigating this contention, identify the drawing, diagrams or documentation relating to ACNGS instrumentation which you have examined.

4. Identify the mistakes which ACNGS operators may make because of the location of instrumentation in the ACNGS control room.

5. State whether TexPirg contends that the control room design for ACNGS is the same as for Three Mile Island ("TMI"). If the answer is no, then explain how alleged problems with control room design at TMI are related to TexPirg's contention that the ACNGS control roon is inadequate.

6. State whether TexPirg contends that the post-accident display instrumentation for ACNGS is the same as for TMI. If the answer is no, explain how alleged problems with post-accident display instrumentation at TMI are related to TexPirg's contention that the ACNGS post-accident display instrumentation is inadequate.

1742 237

7. Specify the " instruments" at TMI which TexPirg claims were defective. State whether TexPirg contends that these same instruments will be used at ACNGS, and if so, provide the source of your answer.

8. Identify the instruments at TMI which TexPirg alleges were improperly located. State whether TexPirg contends that these same instruments will be used at ACNGS, and will be placed in the same location as at TMI, and if so, provide the source of your answer.

9. Produce all documents in TexPirg's possession relating to Interrogatory Nos. El through E8.

10. Identify the person who answered Interroga-tory Nos. El through E8.

11. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

11. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

I742 238 (c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having technical knowledge in the subject area covered by this contention.

F. With respect to TexPirg Additional Contention 30 (regarding charcoal adsorber water sprays) , provide the following information:

1. Specify the design basis accident ("DBA")

referred to in this contention.

2. Explain how a fire would occur in the charcoal filters following this DBA.

3. Specify the amount of iodine which would be released as a result of a fire in the charcoal filters following the DBA identified in F2.

Provide the source of your answer.

I742 239 O

4. Specify the Regulatory Guide referred to in this contention and state why the ACNGS design will not comply with this Regulatory Guide.

5. Identify the provision in the Regulatory Guide identified in F4, which requires Applicant to use water sprays.

6. Describe the work TexPirg has done, whether or not complete, concerning the potential for a fire in charcoal absorber materials at ACNGS.

Furnish copies of the documents which reflect this work, whether or not complete. As used in this question, " work" includes studies you have done, whether or not complete as of the date of your answer to this interrogatory, and documents reflecting discussions with experts and/or prospective witnesses and research.

7. Is it your contention that ACNGS will not meet applicable NRC licensing requirements?

Identify each such requirement which will not be met.

8. Produce all documents which relate to Interrogatory Nos. F1 through F7 hereof.

9. Identify the person who answered Interrogatory Nos. F1 through F7 hereof.

I742 240 s

10. Identify any non-expert witness TexPirg intends

\

to have testify on this contention, and provide a summary of each such witness' testimony.

11. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having the technical knowledge in the subject area covered by this contention.

G. With respect to TexPirg Additional Contention 32 (regarding SDVT float switches) , provide the following information:

1742 241

1. Does TexPirg contend that the ACNGS design incorporates the use of the same float switches as used at the Hatch, Peach Bottom, Duane Arnold and Fermi plants which are referenced in this contention? If the answer is yes, state the source of your answer.

2. If the answer to G1 is no, explain what defects TexPirg alleges to be existent in the present SDVT float switches for ACNGS and provide the source of your answer.

3. Identify the source of the allegation that SDVT float switches failed from 1972 to 1974 at the Hatch, Peach Bottom, Duane Arnold and Fermi plants referenced in this contention.

4. Provide the source of the allegation that "in the event of SCRAM, while the SDVT is filled with water, water from the hydraulic CRD system cannot escape and permit the control rod to be driven into the core as designed, because the rod progress is slowed."

5. State specifically the length of time that control rod drive is slowed by SDVT float switch failure and provide the source of your answer.

1742 242

6. Describe the safety significance of the slow down in control rod drive described in G5, and provide the source of your answer.

7. Produce all documents in TexPirg's possession related to the answers to Interrogatory Nos.

G1 through G6.

8. Identify the person who answered Interrogatory Nos. G1 through G6.

9.. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' tes timony.

10 (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(bL State the qualifications and credentials of each such expert witness.

(c)_ Provide a summary of the testimony which each such witness is expected to offer.

OdL State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

1742 243 (e) Identify the person or persons having the technical knowledge in the subject area covered by this contention.

H. With respect to TexPirg Additional Contentions 34 and 48 (both regarding hydrogen monitoring systems),

provide the following information:

1. Name each gas other than hydrogen which is a "non-condensible gas" (as described in Contention 48) which poses a " chance of an explosion" in the ACNGS containment.

2. State in detail the inadequacies in the present hydrogen sampling subsystems at ACNGS for detection of hydrogen.

3. State whether TexPirg alleges that the hydrogen sampling subsystems are not placed in the proper location, and if not, specify (a) why the present location is inadequate; (b) where the monitors should be located according to TexPirg and how these locations would solve the problems identified in (a).

4. State whether TexPirg has done any calculation in support of the statement (in Contention 34) that " hydrogen explosions will endanger TexPirg 1742 244 members because the containment building during LOCA is likely to contain radio-active gases which would be released from the building damaged even lightly by the explosion and in excess of 40 CFR 190 or 10 CRR 20." If the answer is no, provide the source of this allegation.

5. Does TexPirg contend that the hydrogen moni-toring systems for TMI and ACNGS are the same? If the answer is yes, provide the source of your answer.

6. Does TexPirg contend

• hat the containment design for TMI and ACNGS are the same? If so, provide the source of your answer.'

7. Does TexPirg contend that a hydrogen explosion occurred in the reactor vessel at TMI? If so, what is the source of your answer?

8. Does TexPirg contend that a hydrogen explosion occurred in the containment building at TMI?

If so, (a) describe the damage which occurred at TMI as a result of the explosion; (b) state whether the explosion caused releases in excess of 40 CFR 190 and/or 10 CFR 20; (c) provide the source of your answer.

1742 245

9. State whether the alleged hydrogen explosion at TMI caused: (a) damage to the fuel geometry and (b) physical breaking of fuel rod clad.

Provide the source of your answer.

10. What is the source of the hydrogen which you contend may explode?

11. Identify (by type and/or manufacturer) the system to which you contend Applicant should commit in order to " ascertain accurately how much non-condensible gas is in the reactor vessel."

12. Describe all the work you have done, whether or not complete, on the adequacy of the system at ACNGS to detect concentrations of hydrogen and non-condensible gases. Furnish copies of the documents which reflect this work, whether or not complete. As used in this question,

" work" includes studies you have done, whether or not complete as of the date of your answer to this interrogatory, and documents reflecting discussions with experts and/or prospective witnesses and research.

13. Produce all documents in TexPirg's possession related to Interrogatory Nos. H1 through H12.

1742 246

14. Identify the person who answered Interrogatory Nos. El through H13.

' 15 . Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

16. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having the technical knowledge in the subject area covered by this contention.

I. With respect to TexPirg's Additional Contention 46 (regarding relief valve failure) , provide the following information:

1742 247 -

1. Identify and describe the relief valve design which TexPirg believes to have the least number of recorded failures. Provide the source of your answer.

2. Identifty the " variety of manufacturer's pro-ducts" referred to ir. this contention.

3. Describe the danger resulting from a reduction in the number of relief valves (from 22 to 19),

and provide the source of your answer.

~

4. Provide the source of the information with respect to relief valve failures at TMI, Browns Ferry, Davis-Besse, Dresden and Hatch plants referenced in this contention.

5. Describe the work TexPirg has done, whether or not complete, on the operability of relief valves at ACNGS and other nuclear power plants.

Furnish copies of the documents which reflect this work, whether or not complete. As used in this question, " work" includes studies you have done, whether or not complete as of the date of your answer to this interrogatory, and documents reflecting discussions with experts and/or prospective witnesses and research.

1742 248

6. Produce all documents which relate to Interrogatory Nos. Il through I5.

7. Identify the person who answered Interroga-tory Nos. Il through I5.

8. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

9. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(el Iden: 'fy the person or persons having the technical knowledge in the subject area covered by this contention.

I742 249

J. With respect to TexPirg Additional Contention 47 (regarding outside coolant sampling) , provide the following information:

1. It is your contention that IsCNGS has no system which would permit the taking of a primary coolant sample? If not, identify the deficiency in Applicant's proposed system.

2. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

3. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having the technical knowledge in the subject area covered by this contention.

1742 250 outlines and memoranda, and communications between such experts and Intervenor.

K. With respect to TexPirg Additional Contention 49 (regarding water level indicators), provide the following information:

1. State whether the water level indicators at TMI are the same as those designed for ACNGS, and if not, explain the relationship between water level indicators at TMI and ACNGS.

2. Explain how an erroneous low level indication will result in the water level indicators designed for ACNGS.

3. Explain how " smaller bubbles" are created by a power drop after an MSIV closure followed by SCRAM.

4. Explain why it would be normal operating practice for the operator to increase the feedwater pumpflow ' sic! if the water level indicator is " stuck on low" fellowing a MSIV closure and scram.

5. State whether the steam driven feedwater pumps would be deprived of their motive force when the MSIV's are closed.

I742 251

6. Explain why increasing the feedwater pump flow would lead to " overflow" of the steam line.

7. Explain why increasing the feedwater pumpflow would lead to " water hammer" in the steam line.

8. Produce all documents which relate to Interrogatory Nos. K1 through K7 hereof.

9. Identify the person who answered Interroga-tory Nos. K1 through K7 hereof.

10. Identify any non-expert witness TexPirg intends to have testify on this contention, and provide a summary of each such witness' testimony.

11. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify the person or persons having knowledge in the cubject area covered by this contention.

_31_

1742 252

formulating the expert's opinions and conclu-sions, including workpapers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

Respectfully submitted,

{,/ NV4 he : cf' OF COUNSEL: J.,, Gregory.Copeland '

C ./ Thomas Biddl'e, Jr.

BAKER & BOTTS Charles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY l742 253 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Houston Lighting & Power Company's Fourth Set of Interrogatories and Requests for Production of Documents to TexPirg in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this /9/ day of /2wmfw ,19d.

Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 1742 254

Steve Schinki, Esq. Dorothy F. Carrick Staff Counsel Box 409, Wagon Rd. Rfd. #1 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Carolina Conn John F. Doherty 1414 Scenic Ridge 4327 Alconbury Street Houston, Texas 77043 Houston, Texas 77021 Elinore P. Cumings Robert S. Framson Route 1, Box 138V Madeline Bass Framson Rosenberg, Texas 77471 4822 Waynesboro Houston, Texas 77035 Stephen A. Doggett, Esq.

P. O. Box 592 Carro Hinderstein Rosenberg, Texas 77471

' 8739 Link Terrace Houston, Texas 77025 Robin Griffith 1034 Sally Ann D. Marrack Rosenberg, Texas 77471 420 Mulberry Lane Bellaire, Texas 77401 Leotis Johnston 1407 Scenic Ridge Brenda McCorkle Houston, Texas 77043 6140 Darnell Houston, Texas 77074 Rosemary N. Lemmer 11423 Oak Spring F. H. Potthoff, III Houston, Texas 77043 7200 Shady Villa, #110 Houston, Texas 77055 Kathryn Otto Route 2, Box 61L Wayne E. Rentfro Richmond, Texas 77469 P. O. Box 1335 Rosenberg, Texas 77471 Frances Pavlovic 111 Datonia James M. Scott Bellaire, Texas 77401 8302 Albacore Houston, Texas 77074 Charles Perez 1014 Montrose Bryan L. Baker Houston, Texas 77019 1118 Montrose Houston, Texas 77019 William Schuessler 5810 Darnell J. Morgan Bishop Houston, Texas 77074 11418 Oak Spring Houston, Texas 77043 Patricia L. Strelein Route 2, Box 395C Richmond, Texas 1742 255

Glen Van Slyke 1739 Marshall Houston, Texas 77098 Donald D. Weaver P. O. Drawer V Simonton, Texas 77476 Connie Wilson 11427 Oak Spring Houston, Texas 77043 Clarence Johnson

• Executive Director Texas Public Interest Research Group O n -

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\ / $$/04//v/^) AAY J. Gregory Copeland

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