ML19263E414

Applicant Response to Jf Doherty First Request for Admissions.Denies Officers Have Discussed Permanent Abandonment of Site Because of Aslab 790404 Decision. Affidavit & Certificate of Svc Encl

ML19263E414
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	05/02/1979
From:	Copeland J BAKER & BOTTS
To:
References
NUDOCS 7906180124
Download: ML19263E414 (6)

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UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,./

In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S HOUSTON LIGHTING & POWER COMPANY'S RESPONSE TO JOHN F. DOHERTY'S FIRST REQUEST FOR ADMISSIONS Houston Lighting & Power Company (Applicant) provides herewith its answers to " John F. Doherty's First Request for Admission". These answers are provided without waiver of objections to the relevance of these requests for admission under Rule 26 of the Federal Rules of Civil Procedure and 10 CFR 2.740.

1. Applicant denies that it will not be able to begin construction upon receipt of a construction license for ACNGS.

2. Applicant denies that it will not be able to begin construction in the event it obtains a limited work authoriza-tion pending the outcome of the construction license hearing.

3. Applicant denies that it does not intend to start construction following receipt of a limited work authorization from NRC.

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4. Applicant denies that it does not intend to begin construction of ACNGS immediately upon receipt of a construc-tion permit from the NRC.

5. Applicant denies that it does not pla:: to start construction immediately upon receipt of a constraction license for ACNGS.

~. Applicant denies that it does not plan to start work immediateiv upon receipt of a limited work authorization from the NRC.

7. Applicant denies that it does not intend to start construction for at least one year from April 17, 1979.

8. Applicant denies that it does not intend to start construction for at least one year and six months from April 17, 1979.

9. Applicant denies that it does not intend to start construction for at least two years from April 17, 1979.

10. Applicant denies that it does not intend to start construction for at least three years from April 17, 1979.

11. Applicant denies that it has no date set other than at least three years from April 17, 1979 to start construction on ACNGS.

12. Applicant denies that it has no date to start ACNGS in the next three years.

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13. Applicant denies that its officers have discussed permanent abandonment of ACNGS as a result of the Three Mile Island cccurrence with various groups.

14. Applicant denies that its officers have discussed permanent abandonment of ACNGS because of the April 4, 1979 Appeal Board decision.

Respectfully submitted, I L$fwf/ h J ' Grego'm elsny Attorne for Applicant Ho"uston Lighting & Power Company 2355 190 2

STATE OF TEXAS S COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED ACTHORITY, on this day personally appeared E. A. Turner, who upon his oath stated that he has answered the foregoing Houston Lighting & Power Company's Response to John F. Doherty's First Request for Admissions in his capacity as Vice President for Houston Lighting & Power Company.

. d. . /m-e s E. A. Turner SUBSCRIBED AND SNORN TO BEF RE ME by the said E. A. Turner, on this [ day of y , 1979.

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~ N Nothry Pu"clic in and for Harris County, Texas 2355 191

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby c rtify that copies of the foreg'oing Houston Lighting & Power Company's Response to John F.

Doherty's First Request for Admissions in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this /cd day of M7h , 1979.

d' Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Ccmmission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Ccmmission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gcoch, Esq. Atomic Safety and Licensing Baker & Bctts Board Panel 1701 Pennsylvania A/enue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 2355 192

Steve Schinki, Esq.

Staff Counsel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 John F. Doherty 4438 1/2 Leeland HT2s ton , Texas 77023 Madeline Bass Framson 4822 Waynesboro Drive Houston, Texas 77035 Robert S. Framson 4822 Waynesboro Drive Houston, Texas 77035 Carro Hinderstein 8739 Link Terrace Houston, Texas 77025 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401 Brenda McCorkle 6140 Darnell Houston, Texas 77074 F. H. Potthoff, III 1814 Pine Village Houston, Texas 77080 Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas 77471 James M. Scott, Jr.

8302 Albaccre Houston, Texas 77074 h /* k Y4 ADu Mr'l' 29/J

/J. Gregory'Copelanc

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