ML19296C864
| ML19296C864 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 02/25/1980 |
| From: | Chanania F, Hodgdon A NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8002290002 | |
| Download: ML19296C864 (8) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY NRC Docket Nos. 50-PUBLIC SERVICE BOARD OF SAN ANTONI 50-499A CITY OF AUSTIN
)
M4 CENTRAL POWER AND LIGHT COMPANY
)
(South Texas Project, Unit Nos.
)
and 2)
)
TEXAS UTILITIES GENERATING COMPANY
)
NRC Docket Nos. 50-498A et al.
)
50-499A (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
RESPONSE OF THE NRC STAFF TO THE FOURTH SET OF INTERR0GATORIES FROM HOUSTON LIGHTING & POWER COMPANY TO THE NRC S The NRC Staff hereby responds to the Fourth Set of Interrogatories from Houston Lighting & Power Company ("HL&P"), dated February 1,1980. The answers and information set forth herein are complete, based upon the NRC St=ff's present belief and infomation, as of February 20, 1980. However, si, ce documentary and testimonial discovery is ongoing, the NRC Staff may find it necessary to further update these responses prior to the commence-ment of hearing to include additional infomation, pursuant to 10 CFR S 2.740(e).
1.
Identify all documents which Transcomm Inc., Dr. N. C. Lerner, Rodney W.
Frame, Antoinette Crowder, Kathy Rehbein, or any other Transcormi Inc. em-ployee or consultant has provided to the Staff in connection with this pro-ceeding.
Identify documents in the possession or control of any entity or person named or described in this Interrogatory to which the Staff has or had access, whether or not any such document has ever been in the possession or e
control of the Staff.
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Response
1.
Respcnsive documents have already been produced to HL&P, or are listed, in Appendix B to the Staff's Updated Response to HL&P's Second Set of Interrogatories and Request for Production of Documents and in the Staff's response to the Transcomm subpoena on February 25, 1980. See also Staff's Motion to Modify Subpoena, dated February 25, 1980.
2.
Identify all documents which the Staff has provided to Transcomm Inc., Dr. N.C. Lerner, P.odney W. Frame, Antoinette Crowder, Kathy Rehbein, or any other Transcomm Inc. employee or consultant in connection with this proceeding.
Identify documents in the possession or control of the Staff to which any entity or person named or described in this Interrogatory has or had access, whether or not any such document has ever been in the possession or control of such entity or person.
Response
2.
Responsive documents have already been produced to HL&P, or are listed, in Appendix B to the Staff's Updated Response to HL&P's Second Set of Interrogatories and Request for Production of Documents and in the Staff's response to the Transcom subpoena on February 25, 1980. See also Staff's Motion to Modify Subpoena, dated February 25, 1980.
3.
Identify all Requests for Proposals, proposals, bids, contracts, contract amendments, evaluations, and progress reports which relate to work performed or to be perfonned in connection with this proceeding by Transcomm Inc., Dr. N. C. Lerner, or any other employee of Transcomm Inc.
Response
3.
All responsive documents have already been produced to HL&P, or other-wise listed, in Appendix B to the Staff's Updated Response to HL&P's Second Set of Interrogatories and Request for Production of Documents,
~
. or in the Staff's response to the Transconm subpoena on February 25, 1980.
4.
State the date of each oral communication between the Staff and its expert witness, Dr. N. C. Lerner or any person assisting him in connec-tion with this proceeding, and for each such communication:
(a)
Identify each party thereto; (b) State the subject matter of the communication; (c) State what was said by each party; and (d)
Identify all documents which set forth, contain information about, relate to or were discussed in the communication.
5.
State the date of each oral canmunication between the Staff and its expert witness Robert Hartley or any person assisting him in connection with this proceeding, and for each such communication:
(a)
Iden+ify each party thereto; (b) State the subject matter of the communication; (c) State what was said by each party; and (d)
Identify all documents which set forth; contain information about, relate to or were discussed in the conmunication.
Res ponse:
4.& 5.
The Staff, Mr. Hartley, and Dr. Lerner do not maintain telephone logs or other routine records of oral communications. To the extent that any documents exist which reflect such information, such identified documents have already been produced to HL&P.
In addition, HL&P has already deposed Mr. Hartley and Dr. Lerner once, and will do so again next month. Accordingly, the Staff objects to this interrogatory as unduly burdensome, oppressive, and duplicative.
6.
Identify all documents which contain information about, refer or relate to any of the following memoranda or the purpose for which they were prepa red :
(a) The Transcomm Memorandum to File from Rod Frame dated March 29, 1979, entitled " South Texas Antitrust Case;"
. -(b) The Memorandum to File from Rod Frame dated April 2,1979, entitled "NRC-South Texas Proceeding;"
(c) The Memorandum to Fiie from Rod Frame dated May 15, 1979, entitled "Lambe Memo of 4/6/79-NRC;"
(d) The NP.C Memorandum to Norman Lerner, Transcomm, from William Lambe, NRR-AIG, dated April 6,1979, entitled "Our recent discus-sions with Roy Lessy re: The South Texas case (Prepared in Anti-cipation of a Hearing);" and (e) The Transcomm Memorandum to File from Rodney W. Frame dated June 26,1979, entitled "Anticompetitive Effects of the Intrastate-only Restriction for Texas Electric Utilities".
Res ponse:
6.
These have previously been produced to HL&P in response to the Transcomm subpoena.
See also, Staff's Motion to Modify Subpoena, dated Feburary 25, 1980.
7.
Identify all documents which Robert Hartley or any person assisting him has provided to the Staff in connection with this proceeding.
Identi fy documents in the possession or control of any person named or described in this Interrogatory to which the Staff has or had access, whether or not any such document has ever been in the possession or control of the Staff.
Response
7.
All responsive documents not already made available to HL&P are listed in Appendix A to the Staff's Updated Response to HL&P's Second Set of Interrogatories and Request for Production of Documents.
8.
Identify all documents which the Staff has provided to Robert Hartley or any person assisting him in connection with this proceeding.
Identify documents in the possession or control of the Staff to which any person named or described in this Interrogatory has or had access, whether or not any such document has ever been in the possession or control of such person.
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8.
See Response to interrogatory 7, supra.
Respectfully submitted, Fredric D. Chanania Counsel for NRC Staff
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Ann P. Hodgdon p
Counsel for NRC Staff Dated at Bethesda, Maryland this 25th day of February,1980.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING ROARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY
)
NRC Docket Nos. 50-498A PUBLIC SERVICE BOARD OF SAN ANTONIO
)
50-499A CITY OF AUSTIN
)
CENTRAL FvWER AND LIGHT COMPANY
)
(South Texas Project, Unit Nos.
)
1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
NRC Docket Nos. 50-445A COMPANY, et al.
)
50-446A (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of RESPONSE OF THE NRC STAFF TO THE FOURTH SET 0F INTERROGATORIES FROM HOUSTON LIGHTING & POWER COMPANY TO THE NRC STAFF the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 25th day of February 1980:
Marshall E. Miller, Esq., Chairman Donald A. Kaplan, Esq.
Atomic Safety and Licensing Board Panel Susan B. Cyphert U.S. Nuclear Regulatory Commission Nancy A. Luque Frederick H. Parmenter, Esq.
Washington, D. C.
20555 David A. Dopsovic, Esq.
Michael L. Glaser, Esq.
P. O. Box 14141 1150 Seventeenth Street, N.W.
Washington, D. C.
20044 Washington, D. C.
20036 Mr. William C. Price Sheldon J. Wol fe, Esq.
Central Power & Light Co.
Atomic Safety and Licensing Board Panel P. O. Box 2121 U.S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D. C.
20555 G. W. Oprea, Jr.
Atomic Safety and Licensing Board Executive Vice President U.S. Nuclear Regulatory Commission Houston Lighting & Power Company P. O. Box 1700 Washington, D. C.
20555 Houston, Texas 77001 Docketing and Service Section Office of the Secretary Robert E. Bathen U.S. Nuclear Regulatory Commission R. W. Beck & Associates P. O. Box 6817 Washington, D. C.
20555 Orlando, Florida 32803 R. L. Hancock, Director City of Austin Electric Utility Somervell County Public Library P. O. Box 1088 P. O. Box 417 Austin, Texas 78767 Glen Rose, Texas 76043
.c.
R. Gordon Gooch, Esq.
John P. Mathis, Esq.
Steven R. Hunsickar, Esq.
Jerry L. Harris w
Baker & Botts Richard C. Balough Suite 300 Dan H. Davidson, City Manager 1701 Pennsylvania Avenue, N.W.
City of Austin Washington, D.C.
20006 P. O. Box 1088 Austin, Texas 78767 J.K. Spruce, General Manager City Public Service Board Jerome Saltzman, Chief P.O. Box 1771 Antitrust & Indemnity Group San Antonio, Texas 78203 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Robert C. McDiarmid, Esq.
Robert A. Jablon, Esq.
Jay Galt, Esq.
David A. Giacalone, Esq.
Jack P. Fite, Esq.
Marc R. Poirier, Esq.
Looney, Nichols, Johnson & Hayes Spiegel & McDiarmid 219 Couch Drive 2600 Virginia Avenue, N.W.
Oklahoma City, Oklahoma 73102 Washington, D.C.
20037 Merlyn D. Sampels, Esq.
Jon C. Wood, Esq.
Jos. Irion Wo sham, Esq.
W. Roger Wilson, Esq.
Spencer C. Relyea, Esq.
Matthews, Nowlin, Macfarlane Worsham, Forsythe & Sampels
& Barrett 2001 Bryan Tower, Suite 2500 1500 Alamo National Building Dallas, Texas 75201 San Antonio, Texas 78205 Morgan Hunter, Esq.
Mr. W. N. Woolsey McGinnis, Lochridge & Kilgore Kleberg, Dyer, Redford & Weil Fifth Floor, Texas State Bank Building 1030 Petroleum Tower 900 Congress Avenue Corpus Christi, Texas 78474 Austin, Texas 78701 Dick Terrell Brown, Esq.
Joseph B. Knotts, Esq.
800 Milam Building Nicholas S. Reynolds, Esq.
San Antonio, Texas 78205 Debevoire & Liberman 1200 Seventeenth Street, N.W.
E. William Barnett, Esq.
Washington, D.C.
20036 Charles G. Thrash, Jr., Esq.
Melbert D. Schwarz, Esq.
Douglas F. John, Esq.
Theodore F. Weiss, Esq.
Akin, Gump, Hauer & Feld J. Gregory Copeland, Esq.
1333 New Hampshire Avenue, N.W.
Baker & Botts Suite 400 3000 One Shell Plaza Washington, D.C.
20036 Houston, Texas 77002 Don R. Butler, Esq.
Robert Lowenstein, Esq.
Sneed, Vine, Wilkerson, Selman & Perry J.A. Bouknight, Esq.
P. O. Box 1409 William J. Franklin, Esq.
Austin, Texas 78767 Peter G. Flynn, Esq.
Douglas G. Green, Esq.
John W. Davidson, Esq.
Lowenstein. Newman, Reis, Axelrad Sawtelle, Goode, Davidson & Troilo
& Toll 1100 San Antonio Savings Building 1025 Connecticut Avenue, N.W.
San Antonio, Texas 78205 Wasilington, D.C.
20035 Kevin B. Pratt C. Dennis Ahearn, Esq.
Attorney General's Office Debevoise & Liberman State of Texas 1200 Seventeenth Street, N.W.
P. O. Box 12548 Washington, D.C.
20036 Austin, Texas 78711 James E. Monahan Executive Vice President and General Manager Brazos Electric Power Cooperative, Inc.
P. O. Box 6296 Waco, Texas 76706 Frederick H. Ritts, Esq.
William H. Burchette, Esq.
Law Offices of Northcutt Ely Watergate 600 Building Washington, D. C.
20037 Michael I. Miller, Esq.
James A. Carney, Esq.
Sarah N. Welling, Esq.
Isham, Lincoln & B) ale 4200 One First National Plaza Chicago, Illinois 60603 David M. Stahl, Esq.
Isham, Lincoln & Beale q
0 017 h Street, N.W.
$4/x J4L/
Washington, D.C.
20036 Fredric D. Chanania Counsel for NRC Staff Mr. G. Holman King West Texas Utilities Co.
P. O. Box 841 Abilene, Texas 79604 Maynard Human, General Manager Western Farmers Electric Cooperative P. O. Box 429 Anadarko, Oklahoma 73005 Donald M. Clements', Esq.
Gulf States Utilities Company P. O. Box 2951 Beaumont, Texas 77704 Robert M. Rader, Esq.
Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006
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