ML19270G132

First Request for Admissions from Houston Lighting & Power Co.Certificate of Svc Encl

ML19270G132
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	04/17/1979
From:	Doherty J AFFILIATION NOT ASSIGNED
To:
Shared Package
ML19270G133	List: ML19270G132 ML19270G251
References
NUDOCS 7906050021
Download: ML19270G132 (2)

Text

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an.crto conRESPONDENCE  % 1//7) .':M

.. m .gg U. S. Nuclear Seculatorv Commission " ' Y?"

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I, Sefore the Atomic Safety & Licensinc Board (A3LB) Tggs .

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In the matter of: DN 3w.7 35)

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Houston Lighting & Power Co. ) ccket ;50-4E y_

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W John F. Doherty's First Request for Admissions under 1u CFR 2.74? '- Of /

-on Houston Lighting and Power company. .j' John P. Uoherty, of 4438M Leeland, Houston, 77023, Intervenor O

in the above proceeding propounds the following requests for admi- -

scions undethe Co= mission rules. This intervenor states that ff -

discovery extends until April 17th i.and ine'.uiing th .t date; under . > .

gf the sce.rc*s " Supplemental Order Ruling upon Interventton Petiticis .;

(Page 7) for him.. A'plicant is to reply not less than ten (10) '

days after service of this request. .

1.

Admit or deny that Applicant will not be able to begin construc-tion upon receipt of a Construction License.for ACUGS. .

2. Adait or deny Applicant will not be able to begin construction in the event they obtain a limited work authorisation, pending the out- .

i come of the Construction License Hearing. *

3. Admit or deny Applicant does not intend to start cc;nstruction '

following receipt of a limited work authorisation from liRC?

tt . Adnit or deny Acclicant does not intend to begin construction of AC:!G5 immediately upon receipt of a constructic: ce.ait fr a the NEC.

5. Admit or deny ASplicant does not nian to start c >nstruction i.nmed-iately upon receipt of a Coastruction license for .C UG.i .

6. Ad it or deny Ap41icant does not nlan to start '.tork inacdiately ,

u7en roccipt of a limited work authorisation from the URC.

7. Admit or den 7 apolicant does not intend to start construction  :..

for at least one year from today. ( Y/I7/ M) '

S. Admit or deny a plicant does not iitend to start construction '

for at least one year and six conths fror today. ye <7/71) '

0, Aamit or deny Ap-licant does not intend to start coastruction .-

79060601\

Page 2 for at least two years from today. (4/17/79).

10. Admit or deny Applicant does not iatend to ctart constructica for at least three years from today. (4/17/79).

11 Admit or deny Applicant has no date set other than at least three years from today. (4/17/79), to s~ tart construction on ,

ACNGS.

12. Admit or deny Applicant has no date to start ACNGS in the next three years. ,

13. Admit or den 7 Applicant's officers have discussed permanent abandonement of ACNGS as a result of the Three Mile Island occurence.with various groups.

14 Admit or deny Applicant's officers have discussed permanent abandonement of of ACNGS because of the April 4, 1979 Appeal Board Decision.

Copies of John F. Doherty's First Request for Documents from Houston Lighting & Power Company were served on April 17, 1979, on the below parties (with affiliation). Respectfully submitted, John F. Doherty ,.-

SheldonJ.Wol$,Esq., (NRC), Dr. E Leonard Cheatum, (NRC),

Gustave Linenberger,(NRC), Steve Schinki, Esq. (NRC), Docketing and Service Section (NRC), R. Grodon Gooch, Esq. (Applicant),

J. Gregory Copeland, Esq. (Applicant), Richard A. Lowerre, (Texas),

Carro Hinderstein, Esq., Brenda McCorkle, Esq., James Scott, Esq.

(TEXPIRG).

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