ML19296C725
| ML19296C725 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 02/25/1980 |
| From: | Chanania F NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Green D LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| References | |
| NUDOCS 8002280061 | |
| Download: ML19296C725 (2) | |
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION
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W ASHINGTON, D. C. 20555 y'h/,/
0 February 25, 1980 Douglas G. Green, Esq.
Lowenstein, Newnan, Reis, Axelrad
& Toll 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Re:
Houston Lighting & Power Company, South Texas Project, Unit Nos.1 & 2, NRC Docket Nos. 50-498A and 50-499A; Texas Utilities Generating Company, et al. (Comanche Peak Steam Electric Station, Units 1 & 2), NRC Docket Nos.
50-445A and 50-446A -
Response to Transcomm, Inc. Subpoena
Dear Mr. Green:
The NRC Staff hereby submits, pursuant to agreement of counsel, the response to the Houston Lighting & Power Company subpoena directed to Transcomm, Inc.,
as issued on February 1, 1980:
Paragraph No.1: No further responsive documents; see also NRC Staff's Motion to Modify Subpoena dated February 25,1980 (hereinafter " Staff Motion"),
for objections to this paragraph.
Paragraph No. 2:
"Memorrdum A".is enclosed herewith; "NRC memos" have been previously produced to heap and TU on May 14, 1979 in Appendix C to Staff's Answer to TV's First Set of Interrogatories and Request for Production of Documents; "D0J Letter" is the letter of February 21, 1978 from John H.
Shenefield, Assistant Attorney General, to Howard K. Shapar Executive Legal Director, advising a hearing in NRC Dockets 50-498A, 50-499A (South Texas Project); " petitions, etc." are the formal pleadings in the above-captioned proceedings prior to March 29, 1979. The last three items listed hereinabove are in HL&P's possession, and the Staff believes it unnecessarily duplicative and burdensome to produce them herewith.
Paragraph No. 3: Appendix A enclosed herewith contains the responsive docu-ments which are not already in the possession of HL&P by way of prior pro-ductions by the Staff at and subsequent to Dr. Lerner's deposition; the Staff believes it to be unnecessarily duplicative and burdensome to re-produce documents already produced to HL&P; see also Staff Motion for objections to this paragraph.
80022 8004 l
2 Paragraph.No. 4: Appendix B enclosed herewith contains the responsive docu-ments which are not found in Appendices A and C hereto or which are not already in the possession of HL&P; see also NRC Staff's Updated Response to HL&P's Second Set of Interrogatories and Requests for Production of Documents. All dollar amounts have been covered as the Staff objects to
- heir disclosure and deems them to be proprietary information not in any way calculated to lead to relevant evidence in these proceedings.
Paragraph No. 5:
No responsive documents.
_ Paragraph No. 6: Appendix C enclosed herewith lists the responsive documents, most of which have been already made available to HL&P in earlier productions, in response to other paragraphs of this subpoena, or on discovery in the instant proceedings. The Staff believes it to be unnecessarily duplicative and burdensome to produce again documents alr;ady in HL&P's possession; Staff also objects to this paragraph on the grounds set forth in the Staff Motion.
As to other documents listed, they are available for inspection and copying upon reasonable and timely notice.
Paragraph No. 7:
Responsive documents are provided herewith in Appendix D, except to the extent they, or a listing of them, are othemise provided in response to other paragraphs of the subpoena or are already in the possession of HL&P.
The Staff objects to any further production on the grounds set forth above in response to Paragraph 6; see also the grounds set forth in the Staff Motion.
Paragraph No. 8:
See response to Paragraph 7 above.
Paragraph No. 9:
See response to Paragraphs 3, 4, and 6 above.
Paragraphs No.10-15: The Staff objects to these paragraphs on the gounds set forth in the Staf f Motion; in addition, the Staff objects to the ambiguous and vague character of Paragraph 10, and the unnecessarily repetitive, burdensome, and oppressive requests in Paragraphs 11-15. All responsive documents have been produced to or listed for HL&P.
Yours truly, Fredric D. Chanania Counsel for NRC Staff cc: Frederick K. Slicker, Esq.
w/ attachment Service List w/o attachment