ML19253C737
| ML19253C737 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 11/21/1979 |
| From: | Copeland J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19253C739 | List: |
| References | |
| NUDOCS 7912120056 | |
| Download: ML19253C737 (2) | |
Text
November 21, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
' ' ~
In the Matter of S
v g
HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, Unit 1)
S MOTION FOR LEAVE TO FILE REPLY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY On November 9, 1979, Houston Lighting & Power Company
(" Applicant") filed its Motion to Dismiss TexPirg.
On November 14, 1979, TexPirg filed its Response to Appli-cant's Motion to Dismiss.
TexPirg's Response contains certain factual assertions which directly contradict prior factual assertions made by TexPirg.
Since TexPirg had never before raised these factual assertions, Applicant did not have an opportunity to address them in its Motion to Dismiss.
These assertions go to the very heart of Applicant's Motion and it is important that Applicant be permitted to address those assertions at this time.
For the foregoing reason Applicant respectfully requests that it be permitted to file a reply to TexPirg's Response to Applicant's Motion to Dismiss.
1537 079 g
7912120
Respectfully submitted, b
J" OF COUNSEL:
J Gregopy Cg eland Thomas Biddle, 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 l537 080