ML19259B291
| ML19259B291 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/03/1979 |
| From: | Jablon R, Mcdiarmid R, Poirier M SPIEGEL & MCDIARMID |
| To: | ISHAM, LINCOLN & BEALE |
| Shared Package | |
| ML19259B292 | List: |
| References | |
| NUDOCS 7901260012 | |
| Download: ML19259B291 (2) | |
Text
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law cariCES SPIEGEL & McDIARMID 2600 VIRGINIA AVENUE, N. W.
WASHINGTON. D. C. 20C37 TELEPHONE (202) 333.A500 ROS E RT C. McOI ARMIO OANIEL J. GUTTM AN DAVID R STRAUS SANDRA J. STRE8EL D%G6N
- "* 5 "'"
RoeERT A. JABLON QChhb ROBERT HARLEY SEAR JAMESN HORWOOD ALAN J ROTH THOM AS C. TRAUGER BRANCES E. FRANCl3 CANIEL 8 OAVIOSON JAMEF 2 ARL POLLOCK
?HOM AS N McHUGH. JR.
January 3,
1979 co ch f
Michael I. Miller, Esq.
p.
Richard E.
Powell, Esq.
p
,g\\'
David M.
Stahl, Esq.
gN 4 ISIS F i
Thomas G.
Ryan, Esq.
t Isham, Lincoln & Beale C
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- w One First National Plaza Chicago, Illinois 60603
/
Re:
Houston Lighting and Power Co., et al.
(South Texas Project Units No. 1 and 7),
NRC Docket Nos. 50-498A and 50-499A Gentlemen:
Enclosed is a copy of the Ini 21 Interrogatories to and First Request for Production of Documents by Central Power & Light Company from the Public Utilities Board of the City of Brownsville, Texas, in Houston Lighting and Power Company et al. (South Texas Project, Units No. 1 and 2), NRC Docket Nos. 50-498A and 50-499A.
You will note that many of the questions and requests in this documents require information for all of the Central & South West companies.
It is our belief that under the applicable regulations CP&L should obtain from its af fil-isted companies whatever information is necessary to a complete response.
We will be glad to discuss with you any alternative method you may propose for obtaining this infor-mation.
In any event, we would appreciate your proceeding to respond fully as soon as possible to all questions insof ar as they relate to information about CP&L, or information' in the possession of CP&L.
In draf ting these requests we have tried to take account of the voluminous production that has already occurred in related cases, so as to avoid duplicative 7 9 012 6 0 0 f k
. requests.
Should you feel that a particular request covers the same ground as one to which CP&L has previously responded, please telephone us to discuss the problem.
We would also be glad to answer any other questions you may have about any part of this request.
Very truly yours, n_,
Robert C.
McDiarmid
,/ T~
Robert A.
Jablon
& RL Marc R.
P6irier 3
Attorneys for the Public Utilities Board of the City of Brownsville, Texas cc:
All Parties