ML19261D392
| ML19261D392 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 04/30/1979 |
| From: | Berger M, Clark R, Harris J JUSTICE, DEPT. OF |
| To: | |
| References | |
| NUDOCS 7906190054 | |
| Download: ML19261D392 (6) | |
Text
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UNITED STATES OF AMERICA f/
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a-NUCLEAR REGULATORY COMMISSION Tf
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p-A gyb )$d4.d^'I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1
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In the Matter of
)
)
HOUSTON LIGHTING AND POWER
)
Docket Nos.
0-498A CO4 et al. (South Texas
)
50-49 A Project, Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY (Comanche Peak Steam
)
50-446A Electric Station, Units 1
)
and 2)
)
)
)
REPORT OF THE DEPARTMENT OF JUSTICE - APRIL, 1979 Pursuant to the order dated June 21, 1978, issued by the Atomic Safety and Licensing Board
(" Board"), the Department of Justice (" Department") submits this report on the progress made by the Department in completing discovery during the month of April,1979.
On April 3, 1979, the Department responded to Texas Utilities Generating Company's ("TUGCO's") initial set of interrogatories and document requests.
On the same date, the Department separately responded to Houston Lighting and Power Company's ("HL&P's") second set of interrogatories and document requests.
2308 204 7 906190K7637 4
On April 11, 1979, TUGCO served a partial supplement-al answer to the Department's first set of interrogatories and a request for production of documents.
Following the Prehearing Conference on March 20, 1979, in accordance with this Board's instructions, the Department tried repeatedly to schedule a meeting with counsel for TUGCO and HL&P to discuss compliance by those companies with the Board's orders compelling further answers and the production of additional documents in response to the Department's first set of interrogatories and document requests.
Finally, on April 18, 1979, such a meeting took place at the Department.
During that meeting the Department made every effort to explain its interroga-tories and document requests and to facilitate HL&P's and TUGCO's compliance with the Board's orders.
During the April 18, 1979 meeting, it was decided among counsel that
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HL&P's and TUGCO's further responses and documentary pro-duction would be served by April 27, 1979.
On April 30, 1979, the Department received documents and responses from HL&P and TUGCO.
The Department intends to review these materials to determine whether they constitute full com-pliance with the Board's order.
'In addition to the foregoing, during the month of April, 1979, the Department received copies of, and review-2308 205
ed, transcripts of the depositions taken by Central Power &
Light Company of A.D.
Cyphers, Jr. of DuPont de Nemours and Robert L. Wright of Union Carbide.
Also, the Department has been in contact with counsel for Gulf States Utilities
("GSU") regarding GSU's intentions with respect to the subpoena duces tecum served on it by the City of Brownsville.
Moreover, the Department, pursuant to an informal arrange-ment of counsel, has examined (or received copies of) certain documents in the possession of Brownsville.
Additionally, during the month of April, 1979, the Department received, and began reviewing, documents it had selected for copying during its recently completed examin-ation of documents at the City of Austin.
Finally, the Department continued the process of reviewing other discovery materials already received.
Respectfully submitted, s
N Jddith L. Harris Melvin G. Berger Ronald H.
Clark Frederick H.
Parmenter Attorneys, Energy Section Antitrust Division U.S. Department of Justice Washington, D.C.
20530 Dated: April 30, 1979 2308 206
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 Electric Station, Units 1
)
and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that service of the foregoing REPORT OF THE DEPARTMENT OF JUSTICE - APRIIL, 1979 has been made on the following parties listed hereto this 30th day of April, 1979, by depositing copies thereof in the United States mail, first class, postage prepaid.
Marshall E.
Miller, Esquire Atomic Safety and Licensing Chairman Appeal Board Panel Atomic Safety & Licensing Board U.S. Nuclear Regulatory Panel Commission U.S. Nuclear Regulatory Washington, D.
C.
20555 Commission Washington, D.
C.
20555 Richard S. Salzman. Esquire U.S. Nuclear Regulatory Michael L. Glaser, Escuire Commission 1150 17 th S treet, N.W.
Washington, D.
C.
20555 Washington, D.
C.
20036 Jerome E. Sharfman, Esquire Sheldon J.
Wolfe, Esquire U.S. Nuclear Regulatory Atomic Safety & Licensing Board Commission Panel Washington, D.
C.
20555 U.S. Nuclear Regulatory Commission Chase R. Stephens, Secretary Washington, D.
C.
20555 Docketing and Service Branch U.S. Nuclear Regulatory Samuel J. Chilk, Secretary Commission Office of the Secretary of the Washington, D.
C.
20555 Commission U.S. Nuclear Regulatory Jerome Saltzman Commission Chief, Antitrust and Washington, D.
C.
20555 Indemnity Group U.S. Nuclear Regulatory Commission Washington, D. C.
20555 2308 207
Roff Hardy Michael I. Miller, Esquire Chairman and Chief Executive Richard E. Powell, Esquire Officer David M. Stahl, Esquire Central Power and Light Thomas G.
Ryan, Esquire Company Isham, Lincoln & Beale P. O. Box 2121 One First National Plaza Corpus Christi, Texas 78403 Chicago, Illinois 60603 G. K. Spruce, General Manager Roy P.
Lessy, Esquire City Public Service Board Michael Blume, Esquire P.O. Box 1771 U.S. Nuclear Regulatory San Antonio, Texas 78203 Commission Washington, D. C.
20555 Perry G. Brittain President Jerry L. Harris, Esquire Texas Utilities Generating City Attorney, Company Richard C. Balough, Esquire 2001 Bryan Tower Assistant City Attorney Dallas, Texas 75201 City of Austin P.O. Box 1088 R.L. Hancock, Director Austin, Texas 78767 City of Austin Electric Utility Department P.O.
Box 1088 Robert C. McDiarmid, Esquire Robert A. Jablon, Esquire Austin, Texas 78767 Spiegel and McDiarmid 2600 Virginia Avenue, N.W.
G. W.
Oprea, Jr.
Washington, D. C.
20036 Executive Vice President Houston Lighting & Power Dan H. Davidson Company City Manager P. O. Box 1700 City of Austin Houston, Texas 77001 P. O. Box 1088 Austin, Texas 78767 Jon C. Wood, Esquire W. Roger Wilson, Esquire Don R. Butler, Esquire Matthews, Nowlin, Macfarlane 1225 Southwest Tower
& Barrett Austin, Texas 78701 1500 Alamo National Building San Antonio, Texas 78205 Joseph Irion Worsham, Esquire Merlyn D.
Sampels, Esquire Joseph Gallo, Esquire Spencer C. Relyea, Esquire Richard D. Cudahy, Esquire Worsham, Forsythe & Sampels Robert H.
Loeffler, Esquire 2001 Bryan Tower, Suite 2500 Isham, Lincoln & Beale Dallas, Texas 75201 Suite 701 1050 17th Street, N.W.
Joseph Knotts, Esquire Washington, D.
C.
20036 Nicholas S. Reynolds, Esquire Debevoise & Liberman 1200 17 S treet, N.W.
Washington, D.
C.
20036 2308 208
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Douglas F. John, Esquire R. Gordon Gooch, Esquire Akin, Gump, Hauer & Feld John P. Mathis, Esquire 1333 New Hampshire Avenue, N.W.
Baker & Botts Suite 400 1701 Pennsylvania Avenue, N.W.
Washington, D. C.
20036 Washington, D. C.
20006 Morgan Hunter, Esquire Robert Lowenstein, Esquire McGinnis, Lochridge & Kilgore J.A. Bouknight, Esquire 5th Floor, Texas State Bank William J. Franklin, Esquire Building Lowenstein, Newman, Reis, 900 Congress Avenue Axelrad & Toll Austin, Texas 78701 1025 Connecticut Avenue, N.W.
Washington, D. C.
20036 Jay M. Galt, Esquire Looney, Nichols, Johnson E. W.
Barnett, Esquire
& Hayes Charles G. Thrash, Jr., Esquire 219 Couch Drive J. Gregory Copeland, Esquire Oklahoma City, Oklaho.va 73101 Theodore F. Weiss, Jr., Esquire Baker & Botts Knoland J.
Plucknett 3000 One Shell Plaza Executive Director Houston, Texas 77002 Committee on Power for the Southwest, Inc.
Kevin B.
Pratt, Esquire 5541 East Skelly Drive Assistant Attorney General Tulsa, Oklahoma 74135 P.O. Box 12548 Capital Station John W.
Davidson, Esquire Austin, Texas 78711 Sawtelle, Goode, Davidson
& Tioilo Frederick H.
Ritts, Esquire 1100 San Antonio Savings Law Offices of Northcutt Ely Building Watergate 600 Building San Antonio, Texas 78205 Washington, D.C.
20037 W. S. Robson Ge.,eral Manager Soutis Texas Electric
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Cooperative, Inc.
Route 6, Building 102 Jud4th L. Harris, Attorney Victoria Regional Airport Energy Section Victoria, Texas 77901 Antitrust Division Department of Justice 2308 209
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