ML19257D573
| ML19257D573 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/16/1980 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC., CITIZENS FOR EQUITABLE UTILITIES |
| To: | Schwarz M BAKER & BOTTS |
| Shared Package | |
| ML19257D574 | List: |
| References | |
| NUDOCS 8002050021 | |
| Download: ML19257D573 (2) | |
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dY Mr. Melbert Schwarz, Jr., Esquire Baker and Botts i
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One Shell Plaza Houston, Texas 77002 s'
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Re: Docket Nos. 50-498 50-499 i
Dear Mr. Schwarz:
Citizens Concerned About Nuclear Power, Inc. and Citizens for Equitable Utilities.
Inc.
would like to proceed with the
{g examination and copying of documents at the South Texas Nuclear h..,
Project on Jaauary 24, 25, and 26, 1980. This three day period does include a Saturday (January 26). On behalf of Intervenors, pl I ask that you waive your previous objection to Saturday discovery so that there will be an opportunity to complete discovery without either requiring Intervenors to be away from f
their employment excessively or requiring Intervenors to make f
more than one trip to the project site - a round trip for Intervenors from San Antonio of seven hours, t
On a related matter, Intervenors note your Supplement and Amendment to Applicants' Answers to First Set of Interrogatories j
and Motion for Inspection of Documents by Citizens for Equitable Utilities, et.
al. dated January 11, 1980. In this reply to
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interrogatory number 49, it seems that both Applicants and j
Brown and Root, Inc. now find that they do have documents i
relating to the " alleged altercation" involving James Marshall.
- l The Applicants' documents are at the project site, but the l
Brown and Root, Inc. documents are in Houston. Rather than make 4
s a special t ri p of four hundred (400) miles round t ri p for the j
Brown and Root, Inc. documents, which Intervenors assume are p
not extensive in nature, Intervenors respectfully request that 3
Applicants provide a copy of documents held by Brown and Root.
4 Inc. which relate to interrogatory number 49.
C I look forward to hearing from you.
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For Intervenops 7
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Lanny Alan Sinkin 116 Villita San Antonio, Texas 78205 i.
(512) 226-2959 i
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UNITED STATES OF AMERICA gY?
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I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g
In the Matter of h0USTON LIGHTING AND POWER Docket Nos. 50 498 g
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(South Texas Project i
Units 1 and 2) j R
! hereby certify that copies of " MOTION TO COMPEL APPLICANTS TO Y.
BEAR EXPENSE OF COPYING PURSUANT TO INTERVENOR DISCOVERY" and
" MOTION TO COMPEL APPLICANTS TO PROVIDE DISCOVERY ON SATURDAYS" I' t in the above captioned proceeding have been served on the following by deposit in the United States mail, first class,
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this 16th day of January, 1980:
Charles Bechhoefer. Esq., Chairman Richard W.
Lowerre, Esq.
Atomic Safety and Licensing Board Assistant Attorney General Panel Environmental Protection Div.
U. S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D.C.
20555 Austin, Texas 78711 Dr. James C. Lamb, !!!
Jack R. Newman, Esq.
313 Woodhaven Road Lowenstein, Newman, Reis, Chapel Hill, North Carolina 27514 Axelrad and Toll 1025 Connecticut Avenue Dr. Emmeth A. Luebke Washington, D.C.
20036 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Panel Washington, D.C.
20555 U. S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Henry J. McGurren, Esq.
Counsel for NRC Staff Atomic Safety and Licensing Appeal I
Office of Executive Legal Director Panel Washington, D.C. 20555 U. S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Melbert Schwarz, Jr., Esq.
Baker and Botts Docketing and Service Section (4)
One Shell Plaza Office of the Secretary Houston, Texas 77002 U. S. Nuclear Regulatory Comm.
Mrs. Peggy Buchorn Executive Director Citizens for Equitable Utilities i
Route 1. Box 432 Brazoria, Texas 77422 1
1 Lanny Alan Sinkin Dated: January 16, 1980 6
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