ML19256F212
| ML19256F212 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 12/10/1979 |
| From: | Sohinki S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Doherty J AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 7912170173 | |
| Download: ML19256F212 (2) | |
Text
- pn arog#o, 8
UNITED STATES 8
j NUCLEAR REGULATORY COMMISSION g
5, 9 E WASHINGTON, D. C. 20555 e8
\\..... f December 10, 1979 Mr. John F. Doherty 4327 Alconbury Street Houston, Texas 7702!
In the Matter of Houston Lighting & Power Company (Allens Creek Nuclear Generating Station, Unit 1)
Docket No. 50-466
Dear Mr. Doherty:
While the Staff has already filed answers to all pending interrogatories received from you with regard to your " original" contentions (first - seventh sets),
I am writing to express our dismay regarding your December 3,1979 motion to compel answers.
As you are aware, discovery procedures between the Staff and you have been carried on, until now, quite informally. As you are also aware, the Staff has cooperated with you beyond its legal obligation to do so.
For example, prior to responding to any interrogatories, we could have insisted that you follow the procedure set forth in 10 CFR 92.720(h)(2)(ii).
Further, although we are under no obligation to do so, we have sent substantial numbers of documents to you, many of which are of questionable relevance to issues in this proceeding.
With specific regard to your motion, I have previously had several discussions with you concerning the difficulty which the Staff was having, given other priorities, in responding to your interrogatories.
During our informal dis-cussions, you never raised any objection to the length of time required to fully respond to the proffered questions.
Further, during the prehearing conference in October, I specifically informed you that Staff responses to all pending interrogatories would be filed before the termination of the discovery period set by the Board with regard to the " original" contentions.
You expressed no objection to that procedure.
I, therefore, consider your motion to be a violation of the understanding which I thought we had. At the very least, I would have expected, as a matter of courtesy, that you would call me to discuss the matter prior to filing a motion of this type.
As a collateral matter, the Staff is in receipt of your eighth set of interrogatories to us. However, you have not indicated which interrogatories relate to which contentions, pursuant to our earlier request to you and your commitment to do so 1653 230
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_2 in your postcard sent to me on November 16, 1979.
Therefore, would you please send an addendum to these interrogatories identifying the contention or con-tentions to which each relates. The Staff will calculate its response time from the date of receipt of this information.
Sincerely,
' 41~L Stephen M. Sobinki Counsel for NRC Staff cc: Sheldon J. Woi fe, Esq., Chairman Dr. E. Leonard Cheatum Mr. Gustave A. L..:enberger R. Gordon Gooch, Esq.
J. Gregory Copeland, Esq.
Jack Newman, Esq.
Carro Hinderstein Richard Lowerre, Esq.
Hon. Jerry Sliva, Mayor Hon. John R. Mikeska Mr. and Mrs. Robert S. Framson Mr. F. H. Potthoff, III D. Marrack Texas Public Interest Research Group, Inc.
Brenda A. McCorkle Mr. Wayne Rentfro Rosemary N. Lemmer Charles Andrew Perez Leotis Johnston Mr. William J. Schuessler Margaret Bishop Glen Van Slyke J. Morgan Bishop Stephen A. Doggett, Esq.
Bryan L. Baker Robin Griffith Elinore P. Cummings Mr. Connie Wilson Patricia L. Streilein Carolina Conn Mr. Robert Alexander Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board Docketing and Service Section 1653 231
.