Discovery Rept for Nov 1979.Fifteen Depositions Taken.Third Supplemental Response to Util Second Set of Interrogatories Filed.Doj Filed 791130 Request for Mod of 790724 ASLB OrderML19256F962 |
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South Texas, Comanche Peak |
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12/07/1979 |
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Cyphert S JUSTICE, DEPT. OF |
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To: |
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References |
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NUDOCS 7912270123 |
Download: ML19256F962 (3) |
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Category:DISCOVERY REPORTS
MONTHYEARML20236X3141987-12-0404 December 1987 Supplementation of Discovery Responses.* ML20214R4651986-09-22022 September 1986 Discovery Request for Answers to Interrogatories Re Comanche Peak Response Team.Related Correspondence ML20214R4841986-09-22022 September 1986 Discovery Request for Names of Participants in Review & Analysis of Comanche Peak Response Team.Related Correspondence ML20214Q2851986-09-18018 September 1986 Discovery Rept 12 Requesting Sampling of Applicants Comanche Peak Review Team Plan.Certificate of Svc Encl. Related Correspondence ML20214P7281986-09-18018 September 1986 Discovery Rept 11 Requesting Response to Listed Questions on Encl Nonconformance Repts.Draft Subpoenas for Depositions Also Encl.Related Correspondence ML20214P7101986-09-18018 September 1986 Discovery Rept 10 Requesting Agreement/Disagreement on Listed Statements.Related Correspondence ML20214P7011986-09-18018 September 1986 Discovery Rept 9,App G,Requesting Description of Circumstances Under Which Senior Review Team Directed That Written Description of QA Measures Controlling third-party Activities Be Developed.Related Correspondence ML20214P6941986-09-18018 September 1986 Discovery Rept 8 Re Transcripts of 851003 & 860206 Meetings. Related Correspondence ML20206S5681986-09-16016 September 1986 Discovery Rept 5 Re Rev 2 to App E,Concerning 860723 Questions at Comanche Peak Response Team Public Meeting. Certificate of Svc Encl.Related Correspondence ML20206S5621986-09-16016 September 1986 Discovery Rept 4 Re App B,Requesting Responses to Listed Questions Concerning Comanche Peak Response Team Insp of Qa/Qc Program.Related Correspondence ML20214R8531986-09-16016 September 1986 Discovery Rept 2 Requesting Answers to Listed Questions for Each Listed Individual Re Involvement W/Comanche Peak Response Team from Sept 1984 to Present.Certificate of Svc Encl.Related Correspondence ML20214R8301986-09-16016 September 1986 Discovery Rept 1 Requesting Definitions for Each Separate Meaning or Interpretation Used in Comanche Peak Response Team Program Plan.Related Correspondence ML20214R8081986-09-16016 September 1986 Discovery Instructions Re Applicant Answers to Comanche Peak Response Team Discovery Repts 1 & 2.Related Correspondence ML20206S2631986-09-15015 September 1986 Response Team Discovery 3 Rept Re Program Principles & Objectives.Certificate of Svc Encl.Related Correspondence ML20198A0931986-05-15015 May 1986 Intervenors M Gregory & Case Proposed Discovery Plan,In Response to ASLB 860502 Order Admitting Intervenors as Parties.Related Correspondence ML20010H2091981-09-22022 September 1981 Rept of Applicants & Citizens Association for Sound Energy 810909 Meeting Re Discovery Status.Agreement Reached for Applicants to Supply Intervenors W/New Info & Documents. Certificate of Svc Encl ML19347D6031981-03-18018 March 1981 Supplemental Status Rept of Mar 1981.Settlement Completed W/Central & Southwest Corp & Subsidiaries.Reserves Position That No Administrative or Judicial Proceeding Will Prejudice Brownsville Rights in Future.W/Certificate of Svc ML19330B1371980-07-18018 July 1980 Discovery Rept for June-Jul 1980.Received 800616 Rentfro & Marrack Interrogatories & Replied on 800709.Received 800706 Marrack Motion to Quash Subpoena for Deposition.Deposition Taken by Agreement on 800716.Related Correspondence ML19323H9081980-05-22022 May 1980 Discovery Rept for Apr 1980.Attended Continuation of Nc Lerner Deposition.Responded to Houston Lighting & Power First Set of Interrogatories.Joined Parties Motion for 30- Day Extension.Certificate of Svc Encl ML19324A0461980-05-19019 May 1980 Discovery Rept for Apr 1980.Participated in Gtc Taylor Deposition.Responded to Houston Lighting & Power Motion to Compel Production of Documents.Undertook Settlement Discussions & Trial Preparation.Certificate of Svc Encl ML19323G8981980-05-15015 May 1980 Discovery Rept for Apr 1980.Participated in Nc Learner & G Taylor Depositions.Reveived NRC Updated Response to Houston Lighting & Power Second Set of Interrogatories.Inspected NRC Documents Designated by Expert Witness ML19323G7221980-05-15015 May 1980 Discovery Rept for Apr 1980.Util Counsel Participated in Depositions of Nc Lerner & G Taylor,Expert Economic Witnesses for NRC & Dot,Respectively ML19323H2601980-05-0505 May 1980 Discovery Rept for April 1980.No Discovery Requests Received or Initiated.Certificate of Svc Encl ML19323B7021980-05-0505 May 1980 Discovery Rept for Apr 1980.Deposed Nc Lerner of Transcomm & G Taylor of Doj.Reserved Right to Redepose Nc Lerner. Supplemented Answers to NRC & Central Power & Light Interrogatories.Certificate of Svc Encl ML19323F6071980-05-0101 May 1980 Correction to Apr 1980 Discovery Rept by Public Utils Board of City of Brownsville,Tx.Failure to Depose J Bruggeman Was Due to Counsel Independent Decision to Attend ASLB 800307 Hearing.Certificate of Svc Encl ML19323B7101980-04-30030 April 1980 Discovery Rept by Public Util Board of City of Brownsville, Tx for Apr 1980.Deposed JW Wilson.Participated in G Stagg Deposition.Responded to Houston Lighting & Power Motion to Compel Production of Documents.Certificate of Svc Encl ML19309F3231980-04-25025 April 1980 Discovery Rept for Mar-Apr 1980.Participated in Fj Meyer,Hh Woodson & Gw Stagg Depositions.Filed Opposition to Petitions for Directed Certification & Reversal of ASLB 800307 Order. Joined Other Parties in Moving for Procedural Extension ML19316A8921980-04-21021 April 1980 Discovery Rept for Mar 1980.Participated in D Springs & Gtc Taylor Depositions.Updated Response to Tx Utils Generating Co First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl ML19323H5871980-04-16016 April 1980 Discovery Rept for Mar 1980.No Discovery Requests Initiated or Received.Certificate of Svc & Change of Address Notice Encl ML19323C7911980-04-16016 April 1980 Discovery Rept for Mar 1980.Deposed a Smith,Jw Atkins,Gw Stagg & G Knowles.Participated in J Wenders,Ja Bruggeman & D Springs Depositions.Responded to Houston Lighting & Power Motion Re Expert Testimony of C Stover.W/Certificate of Svc ML19316B0351980-04-15015 April 1980 Discovery Rept for Mar 1980.Participated in J Wenders,A Wood & J Bondurant Depositions.Filed Response to DOJ & NRC Joint Motion for Mod of ASLB Order Re Settlement Discussions. Received Documents from Tx Utils.W/Certificate of Svc ML19323D5641980-04-14014 April 1980 Discovery Rept for Mar 1980.Filed Supplemental Responses to Doj,Central Power & Light & Public Util Board of City of Brownsville,Tx First Sets of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl ML19310A0141980-04-14014 April 1980 Discovery Rept for Mar 1980.Participated in Bruggeman, Wenders,Wilson & Wood Depositions.Filed Supplementary Answers to Central Power & Light First & Third Sets & NRC Initial & Third Interrogatories.W/Certificate of Svc ML19309E3361980-04-0808 April 1980 Discovery Rept for Mar 1980.Deposed Ja Bruggeman,Jt Wenders, Aj Wood & DA Springs.Moved to Compel NRC Deposition of Nd Lerner.Responded to DOJ Motion to Compel Supplemental Answers to First Interrogatories.W/Certificate of Svc ML19309C9581980-03-19019 March 1980 Discovery Rept for Jan-Feb 1980.Participated in M Ozymy Deposition.No Discovery Requests Initiated.Certificate of Svc Encl ML19309C1571980-03-17017 March 1980 Discovery Rept for Feb 1980.Participated in Ammons,Beams, Borchelt,Campbell,& Yarbrough Depositions.Inspected DOJ Documents.Received & Opposed Central & Southwest Motion for Addl Time to Reply to Interrogatories.W/Certificate of Svc ML19309C2621980-03-14014 March 1980 Discovery Rept for Feb 1980.Deposed J Wilson,Gc Campbell & V Robertson Et Al.Attended DOJ & NRC Depositions.Served 800201 First Set of Interrogatories to Nrc.Received Addl Responses to Interrogatories.Certificate of Svc Encl ML19305C8471980-03-0707 March 1980 Discovery Rept for Jan & Feb,1980,City of Austin Has Neither Initialed Nor Received Any Discovery Requests ML19309C9721980-03-0606 March 1980 Discovery Rept by Public Utils Board of City of Brownsville, Tx,For Feb 1980.Deposed M Borchelt of Central Power & Light. Participated in R Edelstein Deposition.Received Documents from Central & South West Corp.Certificate of Svc Encl ML19309D6161980-03-0505 March 1980 Discovery Rept for Feb,1980.City of San Antonio,Acting by & Through City Public Svc Board of San Antonio,Neither Initiated Nor Received Any Discovery Requests.Certificate of Svc Encl ML19309C9531980-03-0505 March 1980 Discovery Rept for Feb 1980.No Discovery Requests Received Nor Initiated.Certificate of Svc Encl ML19309C9211980-03-0505 March 1980 Discovery Rept for Feb 1980.Participated in a Gerber,M Hebb, E Simmons,V Robertson & Gw Beams Depositions.Attended J Turk, & Phillips Depositions.Filed Motion for Addl Time to Respond to Tx Utils Interrogatories.W/Certificate of Svc ML19309C7341980-03-0505 March 1980 Discovery Rept for Feb 1980.Deposed W Taylor,M Hebb,De Simmons & El Watson.Participated in Depositions Noticed by TX-LA Electric Cooperative & City of Brownsville,Tx.Reviewed Diamond Shamrock Documents.Filed Application for Subpoenas ML19305C8131980-03-0404 March 1980 Discovery Rept for Feb 1980.Southwest Tx Electrical Cooperative,Inc & Medina Electric Cooperative,Inc Neither Initiated Nor Received Any Discovery Requests.Certificate of Svc Encl ML19296D2441980-02-26026 February 1980 Discovery Rept for Jan-Feb 1980.Participated in Austin, Hulsey,Brittain,Spence,Hebb & Gerber Depositions.Responded to Houston Lighting & Power Summary Disposition Appeals & Discovery Requests.Prepared Direct Case ML19294B0631980-02-15015 February 1980 Discovery Rept for Jan 1980.Participated in Autry,Beard, Borchelt,Castillion,Chalker,Corder,Farrington & Harrison Depositions.Received Central & Southwest Corp Second Request for Production of Documents.Certificate of Svc Encl ML19294B6341980-02-12012 February 1980 Discovery Rept for Jan 1980.Participated in Houston Lighting & Power Deposition of G Harrison.No Other Discovery Activities Initiated or Received.Certificate of Svc Encl ML19296D1351980-02-0808 February 1980 Discovery Rept for Jan 1980.Deposed TR Locke,O Castillon,R Corder & R Farrington.Participated in J Milford,S Phelps,P Hayers & H Marsh Depositions.Responded to Houston Lighting & Power 800103 Request for Conference Call ML19296A8991980-02-0606 February 1980 Discovery Rept for Jan 1980.Deposed Gr Harrison,Hj Marsh P Hayers,Fj Meyer,Jr Milford,S Phelps & R Segrest.Attended DOJ Depositions.Responded to NRC Third Interrogatories. Served Fourth Set of Discovery to Doj.W/Certificate of Svc ML19294A9261980-02-0505 February 1980 Discovery Status Rept for Jan,1980 Submitted on Behalf of Central & Southwest Corp.Attys Inspected Addl Documents Re Tx Utils Generating Co Response to 790822 Request for Documents.Certificate of Svc Encl 1987-12-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARTXX-9915, Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed1999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20195E1481998-10-0202 October 1998 Confirmatory Order Modifying Licenses NPF-76 & NPF-80 Effective Immediately.Order Confirms Licensee Commitment, as Stated in Ltrs & 0604,to Complete Implementation of Thermo-Lag 330-1 Fire Barriers ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20236V2421998-07-28028 July 1998 Confirmatory Order Modifying License for Plant,Unit 1. Orders That,Effective Immediately,Tu Electric Shall Complete Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Plant ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20094Q4581995-08-31031 August 1995 Exemption from Certain Requirements of 10CFR50,App J to Allow Performance of Required Periodic Type C Tests During Power Operation TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20085N3561995-06-21021 June 1995 Exemption from Requirements of 10CFR50.55a(f)(4)(ii) Re IST During Successive 120-month Intervals ML20085L8531995-06-14014 June 1995 Exemption from Certain Requirements of 10CFR73.55 Re Issuance,Storage & Retrieval of Badges for Personnel Granted Unescorted Access to Protected Areas,Per Util 950327 Application to Implement Geometry Biometric Sys ML20085L5021995-06-0909 June 1995 Exemption Granting One Time Exemption to Permit Schedular Extension of One Cycle for Preformance of App J ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20083M8731995-05-16016 May 1995 Exemption Granted from Certain Requirements of 10CFR73.55,to Implement Hand Geometry Biometric Sys for Site Access Control at Plant Such That Photographic Identification Badges May Be Taken Offsite ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20083A9941994-12-21021 December 1994 Response to Demand for Info (Dfi),Motion for Retraction of DFI & Alternatively,Request for Hearing ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20065L3661994-04-14014 April 1994 Exemption from Requirements of 10CFR50.71(e) to Resubmit Original Pages of FSAR ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals ML20045B8351993-06-0404 June 1993 Directors Decision 93-12 Partially Granting & Partially Denying Petition Filed Under 10CFR2.206,alleging New Evidence of Restrictive Settlement Agreements Entered Into by Util Re Plant ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ST-HL-AE-4428, Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans1993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans 1999-06-18
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UNITED STATES OF AMERICA
.c NUCLEAR REGULATORY COMMISSION 9/.
A!
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD,__
)
In the Matter of
)
)
HOUSTON LIGHTING AND POWER
)
Docket Nos. 50-498A CO, et al (South Texas
)
50-499A Project, Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY (Comanche Peak Steam
)
50-446A s
Electric Station, Units 1
)
and 2)
)
)
REPORT OF THE DEPARTMENT OF JUSTICE - NOVEMBER, 1979 Pursuant to the Order dated June 21, 1978, issued by the Atomic Safety and Licensing Board
(" Board"), the Department of Justice (" Department") hereby submits this Report on the progress made in completing discovery during the month of November, 1979.
During the month of November the Department was involved in a heavy deposition schedule.
The Department deposed:
Name Date Place F. R. Woerner November 14, 1979 Dallas, Texas Wesley Taylor November 16, 1979 Dallas, Texas Barney Phillips November 16, 1979 Houston, Texas In conjunction with the staff of the Nuclear Regulatory Commission the Department deposed:
1645 230 7 0122 70 / 5h 3m
Name Date Place B. G.
Bradley November 9, 1979 Da13as, Texas William Marquardt November 12, 1979 Fort Worth, Texas Jerry Robertson November 13, 1979 Dallas, Texas Si Holt November 28, 1979 Dallas, Texas Louis Fikar November 29, 1979 Dallas, Texas The Department also participated in depositions jointly noticed by Houston Lighting and Power Company ("HL&P") and s
Texas Utilities Generating Company:
Name Date Place Walter Bowers November 1, 1979 Tulsa, Oklahoma R.
H.
Hartley November 2-3, 1979 Washington, D.C.
R.
E.
Roundtree November 12, 1979 Brownsville, Texas L.
R. Gawlik November 12, 1979 Brownsville, Texas H.
E.
Hastings November 13, 1979 Brownsville, Texas I.
Liska November 15, 1979 Brownsville, Texas John H.
Butts November 29, 1979 Tyler, Texas In addition the Department reviewed some of the documents of A. Gerber, HL&P's expert economist, in New York on November 13, 1979 and some of the documents of H. Woodson, HL&P's expert engineer, in Austin, Texas on November 20, 1979 in preparation for their upcoming depositions.
1645 231
On November 27, 1979 the Department filed its Third
~
Supplemental Response of the Department of Justice to the Second Set of Interrogatories and Requests for Production of Documents from Houston Lighting and Power Company to Antitrust Division, U.S. Department of Justice.
On November 30, 1979, the Department. filed a Motion of the Department of Justice For Modification of the July 24, 1979 Order of the Atomic Safety and Licensing Board and s
Application for Issuance of Subpoenas.
Throughout the month of November the Department also continued to analyze discovery material previously received and to prepare for trial.
Respectfully submitted, M
/ Susan B.
Cyphert Frederick H.
Parmenter David A. Dopsovic Nancy Luque Attorneys Energy Section Washington, D.C.
(Telephone:
(202) 724-6667)
December 7, 1979 1645 232