ML19308C997

First Set of Requests for Production of Documents Directed to Nrc.Requests Documents Identified in Response to Houston Lighting & Power 800201 Fourth Interrogatories & Documents Relating to Nc Lerner & R Hartley Testimonies

ML19308C997
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	02/01/1980
From:	Franklin W HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19308C991	List: ML19308C990 ML19308C997 ML19308D002
References
OTHR-800201, NUDOCS 8002130057
Download: ML19308C997 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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HOUSTON LIGHTING & POWER COMPANY, ) Docket Nos. 50-498A

' et al. ) 50-499A-

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(South Texas Project, )

Units 1 and 2) )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445A COMPANY, et al. ) 50-446A

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(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

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FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING & POWER COMPANY TO NRC STAFF Pursuant to Sections 2.720, 2.740, 2.744 and 2.790 of the Commission's Rules of Practice, Houston Lighting

& Power Company propounds the following Requests for Production of Documents to the NRC Staff-(" Staff").

Each document requested should be produced no later than 30 days after service of these Interrogatories and Requests for Production.

Definitions As used herein the terms listed below are, unless otherwise specifically indicated, intended to have the following meanings:

1. "First Set" refers to the First Set of Interroga-tories and Requests for Production of Documents from Houston 800218o OY[

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Lighting & Power Company to NRC Staff, dated October 17, 1978.

2. All Definitions of the First Set are incorporated in these Definitions by reference.

3. "This proceeding" refers to any of the above-captioned dockets.

General Instructions The following General Instructions apply to each of the discovery requests contained herein:

1. Documents in.the possession of any other party to this proceeding or publicly available are not to be regarded as being in Houston's possession.

2. All General Instructions of the First Set are incorporated in these General Instructions by reference.

L Requests for Production

1. Produce all documents identified in any original or supplementary response to the Fourth Set of Interroga-tories from Houston Lighting & Power Compay to NRC Staff, dated February 1, 1980.

2. Produce all draft or proposed testimony, outlines, summaries of testimony, questions and/or answers, or documents relating to testimony of N. C. Lerner.

3. Produce all draft or proposed testimony, outlines, summaries of testimony,' questions and/or answers, or documents relating to testimony of Robert Hartley.

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P Respectfully submitted, William J. Franklin Attorney for Houston Lighting '

& Power Company OF COUNSEL:

Baker & Botts 3000 One Shell Plaza r Houston, Texas 77002 Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, NW Washington, DC 20036 Dated: February 1, 1980 I

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