ML19296D267
| ML19296D267 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 02/26/1980 |
| From: | Chanania F NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8003030129 | |
| Download: ML19296D267 (8) | |
Text
a UNITED STATES OF NiERICA NUCL EAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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 POWER AND LIGHT COMPANY (South Texas Project, Unit Nos.1 and 2)
TEXAS UTILITIES GENERAT4NG COMPANY, NRC Docket Nos. 50-445A et al.
50-446A (Comanche Peak Steam Electric Station, Units 1 and 2)
UPDATED ANSWER OF THE NRC STAFF TO THE FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FROM TEXAS UTILITIES GENERATING COMPANY The NRC Staff hereby updates its earlier Answer of the NRC Staff to the First Set of Interrogatories and Request for Production of Documents from Texas Utilities Generating Company, dated May 14, 1979, based upon its present infonnation and belief, as of February 26, 1980.
1.
(a) Identify each witness, other than an expert witness, whom the Staff expects to or may call in these proceedings and provide a surnary of all matters (including the substance of all facts) as to which each such witness is expec+.ed or or may testify; (b)
Ider,tify all documents upon which each such witness is expected to or may rely in any way, and provide copies of any such document not already in the possession of TUGCO.
Response
1(a)-(b). No change, but see also Updated Response of NRC Staff to the Second Set of Interrogatories and Requests for Production of Documents 8003030\\h
from Houston Lighting & Power Company, No.1(a); Updated Response of NRC Staff to the First Set of Interrogatories and Requests for Production of Documents from Houston Lighting & Power Company, Appendices A-I.
Staff is not able, at this time, to give notice of any documents which are not in TU's possession, but will under-take to give as prompt notice as possible as soon as they are identified.
2.
(a)
Identify each expert witness whom the Staff expects to or may call in these proceedings; (b) State (or produce) the educational and professional qualifica-tions and credentials of each such expert witness; (c) State the subject matter on which the expert is expected to or may testify; (d) Prwide a summary of the testimony which each such witness is expected to or may offer, including the substance of all facts and all opinions to which the expert is expected to or may testify; (e) State the grounds for each opinion each such expert witness expects to or may present in his/her testimony; (f)
Identify all documents prepared by, for, or under the super-vision of each such expert witness, or reviewed or relied upon in any way by such expert in the perfomance of his/her duties, formulation of his/: ar conclusions or opinions, or preparation of his/her testimony, including particularly work papers, status reports, preliminary outlines and memoranda, and communications between such expert and the Staff, any party to the proceeding, or any person with knowledge in any way relied upon by such expert, and provide copies of any such document not already in the possession of TUGC0; (g)
Identify any person affiliated with a party to these proceedings, and each other person from whom infomation was obtained which is in any way relied upon or taken into account by such expert, with whom such expert has communicated; (h)
Prwide a copy of any contracts, letter agreements, or other understandings between the prospective witness or his employer and the Staff which relate in any way to these proceedings; (1)
Identify all documents not produced in response to the fore-going which have been sent or given to the prospective witness or his or her employer or to which his/her/their attention has been directed which relate in any way to these proceedings, and provide copies of any such document not already in the possession of TUGCO.
Res ponse:,
2(a)-(c).
No change, but see also Updated Response of NRC Staff to HL&P's Second Set of Interrogatories and Requests for Produc-tion of Documents, Nos. 2(a), 2(c).
2(d)-(e)
See Updated Response of NRC Staff to the First Set of Inter-rogatories and Requests for Production of Documents from Houston Lighting & Power Company to NRC Staff, dated Febru-ary 11,1980, Nos. 2(d) and 2(e), and see also the transcripts of the depositions of Mr. Hartley and Dr. Lerner taken in the above-captioned proceedings.
2(f)-(g)
See Updated Response of NRC Staff to Houston Lighting & Power Company's Second Set of Interrogatories and Requests for Production of Documents from the NRC Staff, No. 2(f).
2(h).
Documents presently identified as responsive to this request, or a listing thereof, are already in TV's possession.
2(1).
See Updated Response of NRC Staff to Houston Lighting & Power Company's Second Set of Interrogatories and Requests for Production of Documents to NRC Staff, No. 2(f).
4.
(a)
Identify every document or thing which the Staff expects to offer in evidence in these proceedings, other than the testimony of witnesses summarized in response to the preceding interrogatories.
(b)
Produce or make available the documents or things identified in 4.(a) to the extent not already in the possession of TUGCO.
Response
4(a)-(b).
See updated response to interrogatory 1(a)-(b), supra; as set forth in its original answer hereto, Staff is not able, at this time, to give notice of any documents or things which it expects to offer into evidence in these proceedings which are not in TU's possession, but will undertake to give as prompt notice as possible of any such documents or things as soon as they are identified.
7.
With respect to Item 1.a in your response to HL&P's second set of interrogatories and requests for documents, for each individual listed, further detail is required.
Please state the substance of each fact to which the witness is expected to testify, and state whether each such fact relates to Comanche Peak or South Texas or both.
Response
7.
See Updated Answers of NRC Staff to the Second Set of Interrogatories and Requests for Production of Documents from Houston Lighting & Power Company to NRC Staff, dated February 11,1980, Nos.1(a)-(b).
8.
With respect to Dr. Caroline Smith and Carl Stover, listed in your response 1.a.
(a) Prwide curricula vitae (b) state whether these prospective witnesses, identified in your response as expected to be non-expert witnesses, may be proferred as expert witnesses, and (c) if so, please answer intarrogatory and document request number 2 with respect to these individuals.
. 4
Response
8.
The Staff does not intend, at this time, to call Dr. Caroline Smith as a witness.
9.
With respect to (1) Robert H. Hartley, (ii) Noman C. Lerner (both listed in your response to item 2.a of HL&P's second set) and (iii) any additional individuals listed in response to item 2(a) above, (a) list each judicial or administrative proceeding since Janu-ary 1,1970 in which each individual has been proferred as an expert witness, (b) as to each such proceeding, indicate whether he or she was accepted as an expert witness.
(c) List his or her publications.
(d) Provide a copy of his or her testimony as an expert witness in any juducial or administrative proceeding since January 1,1970.
Res ponse:
9.
All material responsive to this request has been made available; see also the transcripts of the depositions of Mr. Hartley and Dr. Lerner taken in the above-captioned proceedings.
Respectfully submitted, 0
Y V.
Fredric D. Chanania Counsel for NRC Staff Dated at Bethesda, Maryland this 26th day of February,1980.
UNITED STATES OF AMERICA
~
NUCLEAR REGULATORY COMMISSION BEFORF THE ATOMIC SAFETY AND LICENSING BOARD 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 POWER 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 UPDATED ANSWER OF THE NRC STAFF TO THE FIibT SET OF INTERR0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FROM TEXAS UTILITIES GENERATING COMPANY in 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 26th 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 Washington, D. C.
20555 Frederick H. Parmenter, Esq.
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 Comission 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 Washington, D. C.
20555 F. O. Box 1700 Houston, Texas 77001 Docketing arid Service Section Office of the Secretary Robert E. Bathen U.S. Nuclear Regulatory Commission R. W. Beck & Associates Washington, D. C.
20555 P. O. Box 6817 Orlando, Florica 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
2 R. Gordon Gooch, Esq.
John P. Mathis, Esq.
Steven R. Hunsicker, Esq.
Jerry L. Harris Baker & Botts Richard C. Balough Suite 300 Dan H. Davidson, City Manager 1701 Pennsylvania Avenue, N.W.
City of Austin Washingtori.. 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 Commissicn 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 Worsham, 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 Debevoise & 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 Washington, D.C.
20036
l,
Kevin B. Pratt C. Dennis Ahearn, Esq.
I Attorney General's Office Debevoise & Libennan l
State of Texas 1200 Seventeenth Street, N.W.
P. O. Box 12548 Washington, D.C.
20036 f
Austin, Texas 78711 James E. Monahan Executive Vice President and General Manager l
Brazos Electric Power Cooperative, Inc.
l P. O. Box 6296 Waco, Texas 76706 l
Frederick H. Ritts, Esq.
i 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 & Beale 4200 One First National Plaza Chicago, Illinois 60603 David M. Stahl, Esq.
Isham, Lincoln & Beale jr Suite 701 A
105017th Street. N.W.
'M 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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