ML19263D653

First Set of Interrogatories & Requests for Production of Documents to Houston Lighting & Power Co Re Site Selection. Certificate of Svc Encl

ML19263D653
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/14/1979
From:	Hinderstein C AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7904130103
Download: ML19263D653 (5)

Text

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OCWggypE00g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S HOUSTON LIGHTING & POWER COMPANY Docket No. 50-46 @ I' e (Allens Creek Nuclear Generating S o Station, Unit 1) 5 s4 07 SY#~ 7 no .s Yp,4g FIRST SET OF INTERROGATORIES AND pg A-REQUESTS FOR PRODUCTION OF DOCUMENTS 4 FROM CARRO HINDE". STEIN, INTERVENOR (h*. N TO HOUSTON LIGHTING & POWER COMPANY Iif ur Pursuant to 10 CFR 52.740(b) and S2.741, Intervenor Carro Hinderstein propounds the following Interrogatories and Requests for Production of Documents to Houston Lighting

& Power Company, hereinafter called " Applicant". Each interrogatory should be answered separately and fully in writing under oath of affirmation by the person or persons making them no later than 14 days after service of these Interrogatories and Requests for Production, and each document requested should be produced no later than 30 days after service of these Interrogatories and Requests for Production.

Each question is instructed to be answered in 8 parts, as follows:

1. Provide the direct answer to the question.

2. Identify all documents and studies, and the particular parts thereof, relied upon by the 790413o103

each such witness expects to present or draw in such expert's testimony.

8. Identify all documents prepared by, for or under the supervision of each such expert witness as identified in part 6 above. Include work papers, preliminary outlines and memoranda and communications between such expert and Applicant that are relied upon by such expert in formulating the expert's opinions and conclusions.

Provide copies of any such documents.

Interrogatories

1. Describe fully all reasons and the weighting system in comparing these reasons ;-i-f any , -used in choosing the Allens Creek site over a site near the Gulf of Mexico.

2. Give the dates and persons involved, Qith title, employer and brief job description), in the decision to start buying land and acquiring easements for the Allens Creek site.

3. Identify the reasons why a site near the Gulf Coast would have been studied less thoroughly in all pertinent fields of inquiry than the Allens Creek site before the Allens Creek site was chosen.

4. State in detail the amount of consideration, and the dates of such consideration and identify the persons who gave such consideration to the mandate from the Office

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_'n Ma-3, Je-3 and Bz-l of the Allens Creek Nuclear Generating Station Alternative Site Evaluation.

Respectfully submitted, fggy 1 ,

Carro Hinderstein b 8739 Link Terrace gcgd Houston, Texas 7702 Q

%g193-4 S ,y CERTIFICATE OF SERVICE Y #p i I hereby certify that copies of the foregoing Interm 'C'i a gatories and Requests for Production of Documents in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery

• this 14th day of March, 1979.

Sheldon J. Wolfe, Chair Richard Lowerre Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U. S. Nuclea Regulatory P. O. Box 12548 Commission Capitol Station Washington, D. C. 20555 Austin, Texas 78711 Dr. E. Leonard Cheatum J. Gregory Copeland Route 3, Box 350A 3000 One Shell Plaza Watkinsville, Georgia 30677 Houston, Texas 77002 Gustave Linenberger Jack R. Newman Atomic Safety and Licensing 1025 Connecticut Ave., N. W.

Board Panel Washington, D. C. 20036 U. S. Nuclear Regulatory Commission James Scott, Jr.

Washington, D. C. 20555 8302 Albacore Houston, Texas 77074 Chase R. Stephens Docketing and Service Section John R. Shreffler Office of the Secretary 5014 Braeburn of the Commission Bellaire, Texas 77401 Nuclear Regulatory Commission Washington, D. C. 20555 Brenda McCorkle*

6140 Darnell -

Steve Schinki Houston, Texas 77074 U. S. Nuclear Regulatory Commission /) 4 e Washington, D. C. 20555 Ldblo Carro Hinderstein