ML19296D244
| ML19296D244 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 02/26/1980 |
| From: | Blume M, Chanania F, Hodgdon A, Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8003030072 | |
| Download: ML19296D244 (2) | |
Text
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'o UNITED STATES
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! !" T NUCLEAR REGULATORY COMMISSION g
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February 26, 1980 Marshall E. Miller, Esq., Chairman Sheldon J. Wolfe, Esq.
Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Michael L. Glaser, Esq.
1150 Seventeenth Street, N.W.
Washington, D.C.
20036 Re: Houston Lighting & Power Company, South Texas Project, Unit Nos.1 & 2, NRC Okt. Nos. 50-498A and 50-499A; Texas Utilities Generating Company, et al.
Comanche Peak Steam Electric Station, Units 1 & 2, NRC Dkt. Nos. 50-445A and 50-446A Gentlemen:
The NRC Staff hereby files its current discovery status report in the above-captioned proceedings.
Since its last discovery status report, NRC Staff personnel have participated in the following depositions: Austin, Hulsey, Brittain, Spence, Greenwade, Jordan, Scarth, Sweatman, McCuistion Simmons, Hebb and Gerber.
For the remainder of February, the Staff anticipates participation in scheduled depositions. The Staff has also participated in obtaining documents from Gulf States Utilities and Dow Chemical Co.
Pursuant to the extension of factual discovery by the Board on the Staff's motion, the Staff further antici-pates participation in the depositions of Gulf States personnel, and any follow-up discovery necessitated thereby.
The NRC Staff has also filed responses to the petitions filed by Houston Lighting & Power and Texas Utilities with the Atomic Safety and Licensing Appeal Board. Those petitions, two interlocutory appeals of this Board's denials of motions for summary disposition and collateral estoppel /res judicata, were filed, respectively, on December 14, 1979 and January 7, 1980.
The NRC Staff has also been engaged in the ongoing responsibility of preparing its direct case. Because of ceri.ain discovery disputes, however, the Staff has been unable to act as expeditiously as it might otherwise have. The Staff was required to re-depose Mr. D.E. Simmons of HL&P on certain factual matters.
In addition, Staff did not receive documents responsive to its Third Set of Interrogatories from HL&P until approximately three weeks after they were due (January 2,1980), without any request for an extension.
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The Staff has also provided TU and Hi.&P with the following answers or up-dated responses to discovery requests:
1.
Answer to HL&P's Third Set of Interrogatories and Request for Production of Documents (1/23/80),
2.
Updated Response to HL&P's First Set of Interrogatories and Request for Production of Documents (2/12/80),
3.
Updated Response to HL&P's Se:ond Set of Interrogatories and Request for Production of Documents (2/25/80),
4.
Updated Answer to TV's First Set of Interrogatories and Request for Production of Documents (2/26/80),
5.
Response tc HL&P's Fourth Set of Interrogatories (2/25/80),
6.
Response to HL&P's First Set of Requests for Production of Documents (2/25/80),
7.
Response to Transcomm subpoena (2/25/80),
In addition, the Staff filed a Motion to Modify HL&P's subpoena directed to Transcomm, Inc. in connection with its response to that subpoena.
Roy Lessy, lead Staff counsel in this matter, has been promoted by the Office of the Executive Legal Director to the position of Assistant Section Chief for Hearing Section III. Accordingly, he will no longer be active in this matter. Effective February 25, 1980, his position will be filled by Fredric D. Chanania.
Respectfully submitted, h
Roy P. Lessy(, IJr.
Counsel for NRC Staff
^ ^ > >
s Fredric D. Chanania Counsel r NRC Staff
-W Michael B. Blume Counsel for NRC Staff O
ow Ann P. Hodgdon Counsel for NRC Staff cc: Service List