ML19291C513
| ML19291C513 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/11/1980 |
| From: | Newman J, Schwarz M, Jason White BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | CITIZENS FOR EQUITABLE UTILITIES |
| References | |
| NUDOCS 8001240528 | |
| Download: ML19291C513 (5) | |
Text
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M UNITED STATES OF AMERICA C
Y' NUCLEAR REGULATORY COMMISSION
]
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' s
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IN THE MATTER OF S
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S HOUSTON LIGHTING & POWER S
DOCKET NOS. STN-498 OL COMPANY, ET AL.
S STN-499 OL S
(South Texas Project S
Units 1 and 2)
S SUPPLEMENT AND AMENDMENT TO APPLICANTS' ANSWERS TO FIRST SET OF INTERROGATORIES AND MOTION FOR INSPECTION AND PRODUCTION OF DOCUMENTS BY CITIZENS FOR EQUITABLE UTILITIES, INC., ET AL.
In accordance with 10 CFR S2.740 (e) Houston Light-ing & Power Company, Project Manager of the South Texas Project, acting on behalf of itself and the other Applicants, the City of San Antonio, Texas, acting by and through the City Public Service Board of the City of San Antonio, Central Power and Light Company and the City of Austin, supplements and amends Applicants' Answer to Interrogatory No. 49 of the First Set of Interrogatories and Motion for Inspection and Production of Documents by Citizens for Equitable Utilities, Inc. (CEU), et al. as follows:
Larry Perry and James Marshall were or are employees of Brown & Root, Inc. and were not employees of any of the Applicants.
Applicants have searched for, but find no documentation of Brown & Root internal investi-gations of alleged beatings of Larry Perry.
Applicants have made inquiries of Brown & Root, Inc. and are informed no such documentation has been located by Brown & Root, Inc.
Both Applicants and Brown & Root, Inc. have documentation with respect to an investiga-tion following an alleged altercation involving James 1793 206 ggo12,,
Marshall.
The documentation of both Applicants and of Brown & Root, Inc. is available for inspec-tion and copying at the Brown & Root Clinton Drive facility (Engineering Southwest Building), 4100 Clinton Drive, Houston, Texas.
Applicants' docu-mentation is also available for inspection and copying at the South Texas Project office off of Farm-to-Market Highway 521 in Matagorda County, Texas.
The substance of this supplement and amendment was made known to Mrs. Peggy Buchorn, Executive Director of CEU, by telephone on January 7, 1980, promptly after the documenta-tion referenced above was located.
CEU was also advised at that time that this documentation would be made available for inspection and copying.
Respectfully submitted,
/
W)7/
/ ^^^ nv14 Relbert D. S6hwarz'
/
C. Thomas Biddle, Jr.
Charles G.
Thrash, Jr.
3000 One Shell Plaza Houston, Texas 77002 Jack R.
Newman Robert H.
Culp 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Attorneys for HOUSTON LIGHTING &
POWER COMPANY, Project Manager of the South Texas Project, acting herein on behalf of OF COUNSEL:
itself and the other Applicants, Baker & Botts THE CITY OF SAN ANTONIO, TEXAS, 3000 One Shell Plaza acting by and through the City Houston, Texas 77002 Public Service Board the City of San Antonio, CENTRAL POWER AND Lowenstein, Newman, Reis, LIGHT COMPANY and THE CITY OF Axelrad & Toll AUSTIN, TEXAS 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 1793 207
STATE OF TEXAS S
S COUNTY OF HARRIS S
BEFORE ME, the undersigned authority, on this day personally appeared J. G. White, who upon his oath stated that he has provided the foregoing supplement and amendment to Answer to Interrogatory No. 49 in his capacity as Super-vising Engineer for Houston Lighting & Power Company, Project Manager of the South Texas Project, on behalf of itself and the other Applicants, and that all statements contained there-in are true and correct to the best of his knowledge and belief.
he h.k/
J.
G. White y SUBSCRIBED AND SWORN TO BEFORE ME by the said J.
G.
White, on this //yL day of January, 1980.
M/
0]bt % v7 Notary Public in and for Harris County, Texas Mv commission expires:
( J)n? / / /? 414 /f,*, /V$0
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j 1793 208
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF S
S HOUSTON LIGHTING & POWER S
DOCKET NOS. STN-498 OL COMPANY, ET AL.
S STN-499 OL S
(South Texas Project S
Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Supplement and Amendment to Applicants' Answers to First Set of Interrogatories and Motion for Inspection and Production of Documents by Citizens for Equitable Utilities, Inc., et al. and were served on the following by deposit in the United States mail, postage prepaid, or by hand delivery this // di day of January, 1980:
Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James C.
Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A.
Luebke Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Henry J.
McGurren, Esq.
Hearing Attorney Office of the Executive Legal Director U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 1793 209
4 Richard W.
Lowerre, Esq.
Assistant Attorney General for the State of Texas P.
O. Box 12548, Capitol Station Austin, Texas 78711 Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 Mrs. Peggy Buchorn, Executive Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 Steven A.
Sinkin, Esq.
116 Villita San Antonio, Texas 78205 Atomic Safety and Licensing Board Panel U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Chase R.
Stephens Docketing and Service Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 sbf f&
Date:
January llM,1980 1793 210