ML19290B661

First Set of Interrogatories & Request for Insp & Production of Documents.Requests Info Re Basis for Section 2.6 of FSAR, Peak Wind Gusts Used for Design & Concrete Bonding Requirements.Certificate of Svc Encl

ML19290B661
Person / Time
Site:	South Texas
Issue date:	11/05/1979
From:	Buchorn P Citizens Concerned About Nuclear Power, INC., CITIZENS FOR EQUITABLE UTILITIES
To:	HOUSTON LIGHTING & POWER CO.
References
NUDOCS 7912130467
Download: ML19290B661 (10)

Text

'

a mTED CORRESPOEMCS UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION N gh 72 :

C7FO*E THE ATOWIC SAETY AND LICENSING BOARD $

y V 3 U1

[

In the Matter of EdSTON LIGHTING AND PCWER CO., g g DOCET NOS. STN 50-498 OL 50-499 OL (Seath Texas Project Units 1 & 2)

CITIZENS FOR EQUITABLE UTILITIES, INC. AND CITIZENS CONCERED ABOUT NUCLEAR POWER FIRST SET OF INTERROCATORIES AND MMION FOR INSPECTION AND PRODUCTION OF DOCUENTS WPSUANT TO le CFR 2.740, CITIZENS FOR EQUITABE UTILITIES, INC., ET AL, REQUEST THAT TE ATTACED IhTERROCATORIES BE ANSERED F1JLLY, IN WRITING, AND UNDER OATH BY APPLICANT OR ANY MER OFFICER OR EMPI4YEE OF TE APPLICAhT OR BRCVN AND ROM VHO HAVE PERSONAL KNOWEDCE THEREOF OR ARE TE CLOSEST TO HAVING ERSONAL KNOWEDGE THEREOF. IF TE Ih"IERROCATORIES ARE ANSWERED, NM ONLY BY STAFF OF APPLICANT OR BROWN AND ROM BUT BY MHER ERSONS, WHETER OR NT E OR SHE HAS VERIFIED TE ANSWERS, AND WETER OR NW E OR SE IS AN OFFICER OR EMFLGEE, SUCH PERSONS NAE, TITIE AND AREA OF RESPONSIBILITY SHOULD E SET FORTH TOGETHER WITH AN IDENTIFICATION OF WHICH INIERROCATORIES E OR SE IS RESPONSIBIE FOR ANSWERING.

PURSUANT TO 10 CFR 2.741, INTERVENORS CEU AND CCANP dEQUEST APPLICAhT AND P40WN AND ROOT TO PERMIT INTERVENORS, AND PERSONS ACTING ON OUR BEHALF, EhTRY TO 1553 163

DOC'JMEh7 STORACE AREAS ON TE STP SITE TO INSIECT AND COPY ANY AND ALL SUCH DOCUMESTS TERTAINING CR RELATED TO THE FOLLOWING IhTERROGATORIES. VE SUCCEST A C0577RENCE CALL INITIATED BY N.R.C. STAFF ATIOREY TO ESTABLISH A TIME MU~JALLY ACREEABIE Oh OR BEFORE DECEMEER 21, 1979.

IN AN EFFORT TO NCfr UNDULY OVERBURDEN TE APPLICAhTS, CEU AND CCANP JOIhTLY SUBMIT THE FOLLOWINC:

1. PROVIDE ACCESS TO ALL DOCUMENTS AND REPORTS, AND THE PARTICULAR PARTS THESE0F, RELIED UPON B,Y TE APPLICAlfr WHICH SERVED AS TE BASIS FOR SECTION 2.6 IN TE FINAL ENVIRONMENTAL STATEMEhT. IN UEU TEREOF, AT APPUCAhTS OPTION,

' A COPY OF EACM SUCH DOCUEhT AND/OR REPORT MAY BE ATTACED TO THE ANSWER,

2. PROVIDE ACCESS TO ALL DOCUMENTS AND REPORTS, AND IDENTIFY PARTICALAR PARTS THEREOF, EXAMINED Bttr NOT RELIED UPON BY TE APPLICANT, WHICH TERTAIN TO TE SUBJECT MATTER QUESTIONED ABOVE. IN UEU TEREOF, AT APPLICAhTS OPITON, A COPY OF EACH SUCH DOCUENT AND/OR REPORT MAY BE ATTACED TO THE ANSWER.

3. IDENTIFY BY NAME, TITIE AND AFFILIATION, EACH PERSON CONTACTED RECARDING TE ABOVE MATIER.

4. IDENTIFY BY NAE, TITLE AND AFFILIATION EACH STAFF, EMPLOYEE OR CONSULTA!rr THAT HAS TE EXPERT KNOWIEDCE REQUIRED TO SUPPORT THE ANSERS TO THE ABOVE QUESTIONS.

5. IDEFTIFY TE EXIERT(S). IF ANY, WHOM THE APPLICANT INIENDS TO HAVE TESTIFY ON TE SUBJECT MATIER QUESTIONED. STATE TE QUAUFICATIONS OF EACH SUCH EXPERT.

6. IS SECTION 2.6.3 0F THE FINAL ENVIRONMENTAL STATEENT REPRESENTATIVE OF ALL SECTIONS OF THIS STATEMENT. IN: (A) ITS ACCURACY, (B) COMPIE1TNESS OF DATA, (C). DEPTH OF RESEARCH AND (D) DECREE OF C0hTACT OR CONCERN FOR IOCAL INFORMATION?

1553 164 2

~

"2 D

]D "]D }@

J o o Ju oJu_J].I!ib

7. WHAT WIND I4ADING IN POUNDS PER SQUARE FOOT WAS USED IN DESIGN OF BUILDINGS AND STRUCTURES? IDENTITY BY NAME, TITE, AFFIUATION AND GUALIFICATION PERSON (S) RESPONSIBIE FOR DESIGN.

8. IESCRIBE YOUR BASIS FOR SAID VIND LOADING, INCLUD7.NG A IETAIIED DISCRIPTION OF THE MATHODOIOGY ITTIUZED TO REACH SUCH CONCLUSION OF WIND -

IDADING.

9. HAVE VIBRATION AND STRESS ANALYSES ON SHAM UNES Br!VEEN CONTAINMENT AND TURBINE GENERATOR BUILDINGS INCLUDED EFFECTS OF HURRICANE WIND LOADINGS?

EXPIAIN.

10. WHAT PEAK VIND GUSTS WERE USED FOR IESIGN? EXFIAIN WHT.

11. REFERENCE S.T.F. UNITS 1 & 2 DRAVINCS NO 1-M- M1b 2 AND 1-M- M16-2 (A) MAS STRESS ANALYSIS OF MITRE JOINTS IN I4V PRESSURE TURBIME EXAUST CONSIDERED THE VARIABI2 FORCES OF HURRICAEE WIND LOADING?

(B) IF SO, WHAT PEAK WIND GUSTS WERE USED FGt IESIGN? IF NOT, WHY?

IDENTITY DOCUMENTS, AND PARTICULAR PARTS THEREOF, REM ED UPON FOR THIS DETERMINATION.

(C) ARE TRAVELING CRANES BRAKED AND ANCHORED FOR HURRICANE WINDS?

IF SO, EXPLAIN HOW. IF NOT, WHY NOT?

12. WHAT EAK HURRICANE WINDS WERE CONSIDERED FOR DESIGN OF OUTSIDE PIPING GENERALLY? -

(A) IDENTIFY ALL DOCUMENTS REMED UPON IN DESICN OF OUTSIDE PIPING.

(B) IDENTIFT ALL DOCUMENTS EXAMINED BUT NOT REUED UPON IN DESIGN OF OUTSIDE PIPING.

(C) WHERE THIS PIPING CONTAINS EXPANSION JOIhTS WHICH ARE PIACED IN

. LAERAL DEFLECTION BY HIGH VIND LOADING, HAVE ALLOWABIE AXI AL LOADS AND DEFIECTIONS BEEN REDUCED?

(D) IF So, PROVIDE METHODOLOGY UTILIZED. IF NOT, WHY NCI"?

(E) HAS ALLOWABIE CYCLES, OR JOINT LIFE BEEN REDUCED? IF SO, PROVIDE METHODOLOGY ITITUZED. IF NOT, WHY NOT? 1553 165 a

oo o- , -

q J o o lh a lu Sl 1 k/ _,

13. VHAT INFLUENCE WILL PEAK HURRICANE WINDS FROM TE EAST HAVE ON STATIC AND DYNAMIC RESISTANCE TO FLOW OF WAER FROM THE TURBIE WATERBOX CONDENSERS THROUGH TE COOLING WAER DISCHARGE STRUCWE? EXPLAIN.

14. CONSIDERING THE ESSENTIAL REQUIREMENT OF CONCREE BONDING WITH REINFORCING BAR, WHAT EVALUATION HAS EEN MAIE OF TE VOIDS AROUND REBAR WERE TE EXISTANCE OF SURFACE VOIDS IS/IS NOT APPARENT?

(A) PROVIDE DOCUMENTATION OF EVALUATION, COMPEN WITH METHODOLOGY f UTILIXED AND RESULTS.

(B) IF NOT YET DONE, PROVIDE EXPLANATION WHY.

(C) UNDER WHAT SECTION OF THE ASME CODE WILL TE CONTAINMENT BUILDINGS BE PRESSURE TESED?

(D) WHAT WILL BE THE EST PRESSURE 7

15. WITH RESECT TO QUESTION 14,14A AND 143. PIEASE PROVIDE TE SAME INFORMATION FOR THE FOLLOWING (A) FUEL HAFDLING BUILDING (B) TURBINE GENERATOR BUILDING (C) ECHANICAL AND EECTRICAL AUXILIARIES BUILDING (D) DIESEL GENERATOR BUILDING (E) DEMINERALIZER BUILDING (F) COOLING WAER INTAKE STRUCTURE

16. HAVE ALL VOIDS EXISTING IN TE CONTAINENT BUILDINGS BEEN LOCAED OR IDENTIFIED?

17. IF NOT, WHY Nor?

18. IF SO, DESCRIBE YOUR BASIS FOR THIS CONCLUSION, INCLUDING A IETAILED DISCRIFFI,0N OF THE METHODOIDGY UTILIZED TO REACH SUCH CONCLUSION.

19. IDENTIFY BY NAE. TITE AND LOCATION THOSE EMPLOYEES OF APPLICANT OR BROWN AND ROOT THAT HAVE PERSONAL KNOVIEDGE REQUIRED TO SUPPORT THE ANSWERS TO QUESTIONS 16 & 17.

1553 166 '

r

20. HAVE THOSE VOIDS THAT HAVE BEEN DISCOVERED BEEN REPAIRED 7

21. IF N W , WHY NOT?

22. IF SO, PROVIDE A DETAIIED DISCRIPTION OF THE ME.THODOLOGY UTILI3D, INCWDING BUT NW LIMIED TO IERRMINATION OF AREA, MATERIAL USED, ESTING 0F MAURIAL, AND QUALITY CONTROL INSPECTION.

23. IDEEIFY BY NAME AND TITE EMPI4YEES OF APPLICAE AND BROWN AhT ROM _

THAT HAVE THE DIRECT KNOVIEDGE REQUIRED TO SUPPORT THE ANSFER 'IV QUESTION 22.

24. PROVIDE ACCESS TO AND/OR DOCUEEATION REIATING TO PLACEMENT INSECTION AND CORRECTIVE EASURES INVOLVINO TAPER TIES USED IN VALIS CF TE C0hTAINEb7 EUILDINGS AS WELL AS TE STRUCTURES NAMED IN QUESTION 15, INCWDING BUT NW

' LIMITED TO DEFICIENCY AND DISPOSITION REPORTS.

25. PROVIDE TESTING CRITERIA. REQUIED FOR THE GROUT FIACED IN TIE-HOIES (A) EMW GRADE oo -

D D c1gD) i3t Tf i (B) ABOVE CRADE oo E Jdu $ jt ._,

26. PROVIDE ACCESS TO AND/0R DOCUENTATION OF CROUTING OF TIE-HOIES IN TE CONTAINMEbi AND FUEL HANDLING BUILDINGS INCLUDING METHOD 014GY UTILIZED.

27. IDENTIFY BY NAME AND TITIE EMPI4YEES OF APPLICANT AND BROWN AND ROM .

THAT HAVE DIRECT KNOWIEDGE REQUIED TO SUPPORT TE ANSWERS TO QUESTIONS 2f+, 25 & 26

28. PROVIDE ACCESS TO AND/OR DOCUENTATION OF PLACEMEhT AND INSPECTION OF WAERPROOF MEMBRANE ON CONTAINMENT AND FUEL HANDLING BUILDINCS.

29. UESCRIBE IN DETAIL THE ETHOD014GY UTILIZED, INCWDING DAES AND TIMES COMPIETED, OF PLACEFINT AND INSECTION OF VATERPROOF MEMBRANE ON ALL CER ST*.UCT. MSS ELCW GRADE.

30. PROVIDE ACCESS TO AND/OR DOCUENTATION OF BACK-FILL ACTIVITIES THAT VOULD IMPACT WATERPROOF MEMBRANE, INCLUDING BUT NW LIMITED TO PIACE. TIME OF DAY /NIOM* AND "'IE REQUIRED FOR COMPIETION.

31. IDENTIFY BY NAME AND TITIE EMPLOYEES OF APPLICAbT AND BROWN AND ROW

"'d.AT HAVE THE DIPICT KNOWLEDCE TO SUPPORT THE ANSVER TO QUESTIONS 28, 29 & 30, 5

1553 167 '

32. PROVIDE ACCESS TO AND/OR DOCUMEhTATICN DEMONSTRATING THAT ADLJATE AND UP-TO-DATE AS-3UILT DRAVINGS AND SIECIFICATIONS ARE AVAILABII TO DETERMINE THE ACn!AL CONDITION; OF CONSTRUCTION EATUP2S RESULTINO FRCM DESIGN CHANCES IN CRITICAL AREAS CF SAFTTY PIIAIED BUILDINGS AND STRUWURES.

33. IDENTIFY B1 NAME AND TITIE EMPI4 TEES OF APPLICAh7 AND BROWN AND ROM WHO ERFORMED THE WORK RELATED TO THE ABOVE QUESTION, INCIEDING BUT NOT UMIIED TO QUALIFICATIONS AND EXPERTISE OF SAID EMPLOYEES.

34. IDENTIFY BY NAME. TITIE AND PRESEE I4 CATION THOSE EMPIDEES OF APPUCAhi AND BROWN AND ROW WHO WORKED ON AS-BUILTS DURING AFRIL, MAY AND JUNE,1979.

35. PROVIDE ACCESS TO AND/OR DOCUMENT 3'1TTILIZED IN TERFORMING VORK REFERRED TO IN QUESTION 34 ABOVE.

36. PROVIDE ACCESS TO AND/OR DOCUMEhTATION DEMONSTRATING THAT PIACEMEhT AND INSPECTION OF STEEL REINFORCING BARS ADHERED TO SPECIFICATIONS IN THE ORIGINAL DESIGN.

37. IF PLACEMENT AND INSPECTION OF REBARS DID NW CORRESPOND WITH SPECIFICA-TIONS IN ORICINAL DESIGN, EXPIAIN JUSTIFICATION FOR CHANCES, INCLUDING RATIONALE PERTAININC THERETO.

38. IDENTIFY BY NAME, TITLE AND PRESENT LOCATION THOSE PERSONS WHO AUTHORIZED ABOVE' CHANCES INCLUDING ,BUT NM LIMIIED TO, QUAUFICATION AND EXFERT KNOWLEDGE UTILI72D.

39. PROV1DE ACCESS TO AND/OR DOCUMENTATION OF INSPEWION OF CADWELDS PRIOR TO CONCRETE POURS IN C0!TTAINMEhT BUILDINGS, INCLUDING BUT NW LIMITED TO, VERIFI-CATION PROCEEDURES Ah3 METHODOLOGY UTILIZED.

40. PIZASE EXPLAIN METHODOIAGY UTILIZED FOR VERIFICATION OF CADWELD IN1ECRITY AND EXACT PLACEMENT IN SAFETY REIAIED STRUCTURES.

41. IDEWIFT BY NAME AND LOCATION EMPLOYEES OF BROWN AND ROCI OR APPUCAh7 VITH DIPSCT KNOVIEDGE TO SUPPORT THE ANSWERS TO QUESTIONS 38 AND 39.

1553 168 6

D 9"D "

Ij) ye c Jn_ 1 Al! ,

42. PROVIDE ACCESS TO AND/OR DOCUMENTATION PERTAINING TO CONCRrrE POURS IN THE COOLING WATER INTAKE STRUCTURE I4CATED IN THE 7,060 ACRE COOLING WATER IAKE, INCLUDING, BUT NOT LIMITED TO, POUR PACKAGES FOR THE M0hTHS OF JANUARY, Fl!:BRUARY AND MARCH, 1979.

43. PLEASE EXPIAIN CRIERIA AND METHODOIOGY ITTILIZED FOR TESTING OF CONCREE, INCLUDING BITT NOT LIMIED TO, AGGRECAM SIEVE AND MOISIURE ANALYSIS, SLUMP AND 3 h

QUALITY CONTROL. ,

44. WHEN CONCREW WAS WMED FRCM GRADE IEVEL TO VARICUS EIGHTS, AT WHAT POINT WAS THE CONCREIE ESED7

45. EIPIAIN METHOD 0I4GY AND ESTING CRIERIA 17 FILI 2ED.

46. PROVIDE DOCUMENT AND/OR ORER REQUIRING THAT CONCRETE BE SAMPIZD AND USED AT IEVEL WHICH CONCREM IS WMND TO, SAID ORDER WAS ISSUED ON OR ABOUT SEPTEMBER 17, 1979.

47. PROVIDE ACCESS TO AND/OR DOCUMENTATION OF NICHT SHIFT INSPECTIONS PRIOR TO 1978.

48. IDENTIFY BY NAME AND PRESENT I4 CATION QUALITY CONTROL INSPECTORS EMPI4YED BY BROWN AND ROOT AT STP DURING 1976,1977 AND 1978, GIVING INFORMATION REIATI!1G TO QUALITICATIONS, TRAINING, AREA 0F RESPONSIBILITY AND IENGTH OF EMPLOYMENT.

49. PROVIDE ACCESS TO AND/OR DOCUMENTATION OF BROWN AND ROUP I ?rERNAL INVESTIGATIONS OF ALIEGED BEATINGS OF LARRY ERRY AND JAMES MARSHALL.

50. PROVIDE DOCUENTS, STATEMENTS OR PAERS OFFEED TO IARRY ERRY OR JAES MARSHALL FOR THEIR SIGNATURES.

51. PROVIDE DOCUMENT, STATEMENT OR PAER OFF4f2> - 00 DAN SWAYZE FOR HIS SIGNATURE PRIOR TO HIS DISMISSAL BY BROWN AS .):<.T.'

52. PROVIDE ACCESS TO AND/OR DOCUMEhMIOP sh <,'.ORRECTIVE ACTION FOLI4 WING SEVERE FLOCDING IN JULY AND SEPIEMBER,1979 INCWDING, FM NOT LIMITED TO, 1553 169 .

7

WATER DEPTH, LISTING OF DAMAGES AND METHOD 01DGY UTILIZED TO MITICATE DAMACES.

53. IDEhTIFY 11 NAME AND TITE EMPLOYEES OF APPLICANT OR EROWN Ah3 ROM WHO HAVE DIRECT KNOVIEDGE TO SUPPORT ANSWER TO QUESTION 52.

54. PROVIDE COPIES OF ALL APPLICANT AND BROWN AND ROM DOCUMENTS INVOLVED AND RETAIED OR COPIED BY F. B. I. AGENTS DURING TE INVESTIGATION OF FAISIFICATION -

0F CONSTRUCTION DOCUEhTS WHICH WAS INITIATED IN JUNE,1979.

55. IDEhTIFY BY NAE AND TITIE EMPLOEES, STAFF OR AITOREYS OF APPLICANT -

AND BROWN AND ROM WHO CAN VERIFY ACCURACY OF TE ANSWER TO QUESTION 54

56. PROVIDE ACCESS TO AND/03 DOCUMEhTS, AND TE PARTICULAR PARTS TEEOF, RELIED UPON BY THE APPLICAhT WHICH SERVED AS TE BASIS FOR SECTIONS 3 5 AhT 5.4 AND RELAITD TABIES IN TE F.E.S.

57. PROVIDE ACCESS TO AND/OR DOCUMENTS, AND THE PARTICUIAR PARTS TEPIOF, EXAMINED BUT NM RELIED UPON WHICH PERTAIN TO TE SUBJECT MAMER REFERRED TO IN THE PREVIOUS QUESTION,

58. IDENTIFY BY NAME, TITIE, AND AFFILIATION EACH EMPLOYEE OR CONSULTAh?

THAT HAS TE EXEERT KNCMIIDGE REQUIRED TO SUPPORT TE ANSVEPS TO QUESTIONS 56 Ah3 57.

59. PROVIDE ACESS TO AND/OR DOCUEhTS, AND THE PARTICULAR PARTS THEREOF, RELIED UPON BY TE APPLICAh7 WHICH SERVED AS THE BASIS FOR SECTIONS 4.1 AhT 5.3 AND RELATED TABLES IN TE F.E.S. .

60. PROVIDE ACESS TO AND/OR DOCUMENTS, AND TE PARTICUIAR PARTS TEREOF, EXAMINED BUT NM RELIED UPON WHICH IERTAIN TO TE SUBJECT MAITER REFERRED TO IN TE PEVIOUS QUESTION.

61. PROVIDE ACCESS TO AND/OR DOCUMENTATION OF ANY A'iD ALL SOIL 'ITSTS, CORES, SUBSIDENCE STUDIES, SETTIEMENT CAIfUIATIONS AND RELATED DOCUMEhTS CONCERNING SOIL MAKEUP PERFORMED PRIOR TO OR DURING CONSTRUCTION ACTIVITIES.

1553 170 8

62. IDENTIFY BY NAME, TITI2 AND AFILIATION EACH EMPLOYEE OR CONSULTANT THAT HAS THE EXERT KNOWIEDGE RE UIRED TO SUPPORT THE ANSWER TO QUESTION 61.

63. PROVIDE ACCESS TO AND/OR DOCUMENTATION OF SOIL MOVING ACTIVITIES RFIAED TO PREPARATION OF COOLING IAKE AND SURROUNDING DAM INCLUDING, BUT NC7f LIMIED TO, DEPTH OF EXCAVATION, SOIL MAKEUP, ESTING AND INSECTIONS, (A. IDEhTIFY BY NAME TITIE AND PRESENT LOCATION PERSONS WITH ERSONAL KNOWIEDGE AND EXPERTISE NECESSARY TO VERIFY THE ANSWER TO QUESTION 63.

RESPECTFULLY SUBMITIED

%& M

'MRS. PEGGY @BCRORN 1553 171 9

9

I HEREBY CERTIFY THAT COPIES OF THE FOKEGOING DOCUMENT HAVE BEEN SERVED ON ALL PARTIES TO THIS DOCKET BY DEPOSIT IN THE U. S. MAIL THIS DAY OF NOVEMBER, 1979 ra ra m rq r J o o ju oJu,SJktru_,

CHARIES BECHHOEFER, ESQ., CHAIRMAN 53. CHASE R. SITPHENS ATmIC SAFETY AND LICENSING BOARD DOCKETING AND SERVICE SECTION U. S. NUCIEAR BEGUIATORY COMMISSION OFFICE OF TE SECEETARY CF TE C000'SSION WASHINGTON, D. C. 28555 U. S. NUCIEAR REGUIATORI CmMISSION VASENGTON, D. C. 28555 DR. JAMES C. LAMB, III 313 V00DHAVEN ROAD HONMAErz BURT O'CONNELL CHAEL HILL, NCRTH CAROLINA 27514 COUNTY JUDGE, MATAGORDA CCUNTY MATAGORDA COUNTY COURT HOUSE -

DR. EMMETH A. LUESKE BAT CITT, TEIAS 77414 ATWIC SAPTTT AND LICENSING BOARD U. S. NUCIEAR REGUIATORY COMMISSION R. GORDON GOOCH, ESQUIRE WASHINGTON, D. C. 2*555 1791 PENNSTLYANIA AVENUE, N. V.

VASHINGT W , D. C. 20446 E NRY J. McCURREN, ESQUIRE HEARING ATTORNET Steven A. Sinkin' Esq' OFFICE OF TE EXECUTIVE IEGAL DIRECTOR 116 Villita

U. S. NUCIEAR REGUIATORY CmMISION San Antonio, Texas 78205 VASHINCr0N, D. C. 28555 . .

RICHARD V. IM ERE , ESQUIRE MELBERT SCHWARZ, JR. ES9.

ASSISTANT ATICENET GENERAL, STATE OF TEZAS 3AKER AND BOITS P. O. BOI 12548 ONE SHELL PLAZA CAPITOL STATION HOUSTON , TEIAS 77002 ADSTIN, TEIAS 78711 JACK R. NEVMAN, ESQ.

LOWENSTEIN, NEVMAN, REIS & ATET. RAM le25 CONNECTICUIT AVENUE, I.V.

WASHINGT G , D. C. 29436 W 6161M /

V//

MRS. ECCY BUCHORN, EXEC. DIR.

- CITIZENS FOR EQUITABLE UTILITIES, INC.

e

- M 1553 172 e-f,;#,[:_2 /

p q

~

g wamowCg

• sn .