ML19294C087

Motion for Protective Order Compelling Citizens Concerned About Nuclear Power to Respond to 800125 Interrogatories. Interrogatories Were Due on 800225.Certificate of Svc Encl

ML19294C087
Person / Time
Site:	South Texas
Issue date:	02/25/1980
From:	Biddle C, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8003060660
Download: ML19294C087 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ', d( ' 5 p

' ,% ,s BEFORE THE ATOMIC SAFETY AND LICENSING BOARDJC12 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) S APPLICANTS' MOTION FOR ORDER COMPELLING CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC.

TO RESPOND TO INTERROGATORIES On January 25, 1980, the Applicants filed a series of interrogatories directed to Citizens Concerned About Nuclear Power, Inc. (CCANP) in the above-captioned pro-ceeding. The discovery schedule established by this Board in the Memorandum and Order dated August 3, 1979, provides that the responses to these interrogatories were to be filed by CCANP on or before February 25, 1980.

As of this date, the Applicants have received no responses to these interrogatories. Since the answers to the Applicants' interrogatories were not filed within the prescribed time period, nor timely objections interposed, the Applicants respectfully request, pursuant to 10 C.F.R.,

S 2.740 (f) , the Licensing Board issue an order compelling 8003060(h5/C'

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CCANP to fully answer the Applicants' interrogatories dated January 25, 1980.

Respectfully submitted, OF COUNSEL:

e %es &iM yh Melbert D. Schwarz C. Thomas Biddle, Jr.

Baker & Botts Charles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 Lowenstein, Newman, Reis, Jack R. Newman Axelrad & Toll Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Washington, D.C. 20036 Attorneys for HOUSTON LIGHTING &

POWER COMPANY, Project Manager of the South Texas Project, acting herein on behalf of it-self 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 1F AUSTIN, TEXAS

/ .

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) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicants' Motion for Order Compelling Citizens Concerned About Nuclear Power, Inc., to Respond to Interrogatories in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 25th day of February, 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 Richard W. Lowerre, Esq.

Assistant Attorney General for the State of Texas P. O. Box 12548, Capitol Station Austin, Texas 78711

/ w Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court Housa 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 7,I ,

C. Thomas Biddle, Jr.

February. 25, 1980