ML19263C412
| ML19263C412 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 02/02/1979 |
| From: | Knotts J DEBEVOISE & LIBERMAN |
| To: | |
| References | |
| NUDOCS 7902220080 | |
| Download: ML19263C412 (5) | |
Text
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- ,tC"'!ENf ilOOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of HOUSTON LIGHTING AND POWER CO.,
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Docket Nos. 50-498A et al.
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50-429A (South Texas Project, Units (j j-
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C TEXAS UTILITIES GENERATING g/
6 Docket Nos. 50-445A COMPANY, et al.
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s 50-446A (Comanche Peak Steam Electric h f x a~
Station, Units 1 and 2)
Y!S REPORT OF TUGCO, et al.,
- JANUARY, 1979 Pursuant to the direction of the Atomic Safety and Licensing Board during the Special Prehearing Conference on June 21, 1978 (Tr. 124-125) in South Texas, and during the conferences in Comanche Peak and South Texas on December 5, 1978 (Tr. 79-90),
TUGCO submits this report on discovery during the month of January, 1979.
During January, TUGCO rece_ved from the Justice Department further inquiries regarding documents produced in October, 1978 and further requests for clarification regarding various matters pertaining to TUGCO's assertion of privilege with respect to certain documents.
TUGCO plan to respond shortly.
On January 12, 1979, TUGCO filed its answer to the Depart-ment's First Set of Interrogatories and Requests for Production of Documents as well as a separate document objecting to, and moving for protective orders regarding, certain of the Department's interrogatories and requests for production.
79022200fo
TUGCO also received during January the NRC Staff's first set of interrogatories and requests for production of documents.
An extension until March 5, 1979 for TUGCO's response was sought and has been approved by the Licensing Board in its Order of January 31, 1979.
Also during January, a representative of the City of Brownsville engaged in extensive review of documents in the offices of TU and its operating subsidiaries in Dallas and in Fort Worth.
Finally, during the month of January, a set of discovery materials (the documents selected for copying by NRC and the Department from TUGCO documents involved in discovery in the District Court litigation), which had previously been loaned to counsel for Brownsville, were loaned to counsel for Tex-La for their review.
Although not in the category of discovery, a major develop-ment during the month of January was the issuance by the District Court in Dallas of its Memorandum Opinion in West Texas Utilities Company and Central Power and Light Company vs. Texas Electric Service Company and Houston Lighting and Power Company.
We under-stand that counsel for Houston Lighting and Power Company has pro-vided copies to the Board and the Parties on the combined Comanche Peak and South Texas service lists.
Respectfully submitted,
~
.Toseph B.
Knotts, Jr.
DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 Dated:
February 2, 1979
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
HOUSTON LILHTING AND POWER CO.,
)
Docket Nos. 50-498A 31 al.
)
50-499A
)
(South Texas Project, Units
)
1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
)
Docket Nos. 50-445A
)
50-446A (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the " Report of TUGCO, et al.,
- January, 1979" was served upon the following persons by deposit in the United States mail, first class postage prepaid, this 2nd day of February, 1979.
Marshall E.
Miller, Esq.
Mr. Jerome D.
Saltzman U.S.
Nuclear Regulatory Chief, Antitrust and Commission Indemnity Group Washington, D.C.
20555 Nuclear Reactor Regulation U.S.
Nuclear Regulatory Michael L.
Glaser, Esq.
Commission 1150 17th Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20036 J.
Irion Worsham, Esq.
Sheldon J.
Wolf, Esq.
Merlyn D.
Sampels, Esq.
U.S.
Nuclear Regulatory Spencer C.
Relyea, Esq.
Commission Worsham, Forsythe & Sampels Washington, D.C.
20555 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Atomic Safety and Licensing Appeal Board Panel Jon C. Wood, Esq.
U.S.
Nuclear Regulatory W.
Roger Wilson, Esq.
Commission Matthews, Nowlin, Macfarlane &
Washington, D.C.
20555 Barrett 1500 Alamo National Building Chase R.
Stephens San Antonio, Texas 78205 Docketing and Service Branch U.S.
Nuclear Regulatory Charles G.
- Thrash, Jr., Esq.
Commission E.W.
Barnett, Esq.
Washington, D.C.
20555 Theodore F.
Weiss, Esq.
J.
Gregory Copeland, Esq.
Baker & Botts 3000 One Shell Plaza Houston, Texas 77002
R.
Gordon Gooch, Esq.
Jerry L.
Harris, Esq.
John P.
Mathis, Esq.
Richard C.
Balough, Esq.
Baker & Botts City of Austin 1701 Pennsylvania Avenue, NW P.O.
Box 1088 Washington, D.C.
20006 Austin, Texas 78767 Roy P.
Lessy, Jr., Esq.
Don H.
Davidson Michael B.
Blume, Esq.
City Manager U.S.
Nuclear Regulatory City of Austin Commission P.O.
Box 1088 Washington, D.C.
20555 Austin, Texas 78767 Roff Hardy Robert Lowenstein Chairman and Chief Executive J.A.
Bouknight, Jr.
Officer William J.
Franklin Central Powel and Light Company Lowenstein, Newman, Reis &
P.O.
Box 2121 Axelrad Corpus Christi, Texas 78403 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Mr Perry G.
Brittain President John W.
Davidson, Esq.
Texas Utilities Generating Sawtelle, Goode, Davidson &
Company Tioilo 2001 Bryan Tower 1100 San Antonio Savings Dallas, Texas 75201 Building San Antonio, Texas 78205 R.L.
Hancock, Director City of Austin Electric Utility Douglas F.
John, Esq.
P.O.
Box 1086 Akin, Gump, Haver & Feld Austin, Texas 78767 1100 Madison Office Building 1155 15th Street, N.W.
G.W.
Oprea, Jr.
Washington, D.C.
20005 Executive Vice President Houston Lighting & Power Morgan Hunter, Esq.
Company McGinnis, Lockridge & Kilgore P.O.
Box 1700 Fifth Floor, Texas State Houston, Texas 77001 Bank Building 900 Congress Avenue Judith Harris, Esq.
Austin, Texas 78701 Ronald Clark, Esq.
U.S.
Department of Justice Richard D.
Cudahy, Esq.
Antitrust Division Joseph Gallo, Esq.
P.O.
Box 14141 Robert H.
Leoffler, Esq.
Washington, D.C.
20044 Isham, Lincoln & Beale 1050 17th Street, N.W.
Don R.
Butler, Esq.
Suite 701 Sneed, Vine, Wilkerson, Washington, D.C.
20036 Selman & Perry P.O.
Michael I. Miller, Esq.
Kevin B.
Pratt Richard E.
Powell, Esq.
Attorney General's Office David M.
Stahl, Esq.
State of Texas Thomas G.
Ryan, Esq.
P.O.
Box 12548 Isham, Lincoln & Beale Austin, Texas 78711 One First National Plaza Chicago, Illinois 60603 Frederick H.
Ritts, Esq.
William H.
Burchett, Esq.
Bill D.
St. Clair, Esq.
Northcutt Ely McGinnis, Lockridge & Kilgore Watergate 600 Building Fifth Floor, Texas State Bank Washington, D.C.
20037 Building 900 Congress Avenue Austin, Texas 78701 W.S.
Robson General Manager South Texas Electric Cooperation, Inc.
Route 6, Building 102 Victoria Regional Airport Victoria, Texas 77901 Robert C.
McDiarmid, Esq.
Robert Jablon, Esq.
2600 Virginia Avenue, N.W.
Washington, D.C.
20037
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Joseph B.
- Knotts, Jr.