ML19263D584
| ML19263D584 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 04/02/1979 |
| From: | Franklin W LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Glaser M, Mark Miller, Wolfe S Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19263D585 | List: |
| References | |
| NUDOCS 7904130038 | |
| Download: ML19263D584 (2) | |
Text
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~ f I no Marshall E. Miller, Esq.
Michael L.
Glaser, Esq.
Sheldon J.
Wolfe, Esq.
Atomic Safety and Licensing Board Panel U.S.
Nuclear R.egulatory Commission Washington, D.C.
20555 Re:
Houston Lighting & Power Company South Texas Project, Units 1 and 2 (Docket Nos. 50-498A and 50-499A)
Gentlemen:
This is the March 1979 discovery progress report of Houston Lighting & Power Company.
On March 7, Houston responded to Brownsville's first set of interrogatories and requests for production of documents with answers, objections, and a motion for a protective order.
On March 21 Brownsville filed a precautionary motion for an extension of time in which to respond to this motion, as Brownsville and Houston are working informally to resolve differences.
On March 26 Houston fik d a motion to compel the NRC Staff to make fuller responses to Houston's second set of interroga-tories and requests for production of documents.
The Staff had responded to these interrogatories on March 12.
Also on March 26 Houston filed a defensive motion for an extension of time in which to respond to the Staff's March 23. motion to compel Houston to make further answers to the Staff'r, interrogatories and requests for production.
The Staff and Fouston are working informally to resolve apparent problems.
790413 Co 3 E
1.OW E N ST E I N, N EW M A N, }{ E t h. A X E E.H A n & To r.r.
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Marshall E. Miller, Esq.
Michael L. Glaser, Esec Sheldon J. Wolfe, Esq..
Page Two April 2, 1979 On March 26, Central Power & Light Company (CP&L) served answers and objections in response to Houston's first set of interrogatories and requests for production of documents.
Houston is in the process of reviewing CP&L's response, and enclosed with this progress report is Houston's motion for an extension of time in which to file a motion to compel further production.
During the month Houston and CP&L agreed to a draft protective order of confidentiality with respect to documents which CP&L has produced or will produce to Houston, and the Board so ordered on March 23.
On March 27, Houston served answers and objections in response to CP&L's second set of interrogatories and requests for production of documents.
During the month Houston has been preparing additional answers and document production for the Antitrust Division's interrogatories and requests for production as a result of the Board's March 6 and March 12 Orders.
Houston is also preparing rer;ponses as the Board ordered at the March 20 prehearing conference.
Finally, during the month Houston has continued to work informally cn discovery with the Antitrust Division, the NRC Staff, Brownsville, and other parties upon request.
Respectfully submitted, William J.
ranklin Attorney for Houston Lighting &
Power Company WJF/gd cc:
Attached service list