ML19309C706
| ML19309C706 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 03/11/1980 |
| From: | Slicker F TEXAS UTILITIES CO., WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8004090175 | |
| Download: ML19309C706 (3) | |
Text
e.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD geket Nos. 50-498A IN THE MATTER OF o
50-499A HOUSTON LIGHTING & POWER cum.o COMPANY, PUBLIC SERVICE uwa FAS N
CEI b
t/fdl21 MO>
AND LIGHT COMPANY Di u d esscatr/
(South Texas Project, Unit Dddgasmica Nos. 1 and 2)
Ermh P
c, 6
TEXAS UTILITIES GENERATING A
COMPANY, et al.
NRC Docket Nos. 50-445A (Comanche Peak Steam Electric :
50-446A Station, Units 1 and 2)
SUPPLEMENTAL ANSWERS OF TEXAS UTILITIES COMPANY AND ITS SUBSIDIARIES TO THE NRC STAFF'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS PROPOUNDED TO HOUSTON LIGHTING & POTER COMPANY AND TEXAS UTILITIES GENERATING COMPANY COME NOW TEXAS UTILITIES COMPANY ("TU"), TEXAS UTILITIES GENERATING COMPANY ("TUGC0"), DALLAS PO'4R & LIGHT COMPANY ("DPL"),
TEXAS ELECTRIC SERVICE COMPANY ("TESC0"), and TEXAS POWER & LIGHT COMPANY ("TPL"), all collectively referred to as "TU Companies",
in compliance with Section 2.740b and 2.741 of the Rules of Prac-tice of the Nuclear Regulatory Commission ("NRC"), and make the following supplemental answers to the NRC Staff's Third Set of Interrogatories and Requests for Production of Documents Propounded to Houston Lighting & Power Company and Texas Utilities Generating Company.
These answers are in addition to answers given and documents produced in response to interrogatories and during depositions of employees of a Texas Utilities Company.
Sunclemental Answer to Interrogatorv No. 18:
See document attached hereto.
a 8004000 jg6
Respectfully submitted, Jos. Irion Worsham, Esq.
M. D. Sampels, Esq.
Frederick K. Slicker, Esq.
WORSHAM, FORSYTHE & SAMPELS 2001 Bryan Tower, Suite 2500
~
Dallas, Texas 75201 Joseph B. Knotts, Jr., Esq.
Nicholas S. Reynolds, Esq.
DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
200 By Frederick K. Slicker ATTORNEYS FOR TEXAS UTILITIES COMPANY, TEXAS UTILITIES GENERATING COMPANY, DALLAS POWER & LIGHT COMPANY, TEXAS ELECTRIC SERVICE COMPANY, AND TEXAS POWER & LIGHT COMPANY
~
THE STATE OF TE:GS COUNTY OF DALLAS BEFORE ME, the undersigned authority, a Notary Public in and for Dallas County, Texas, on this day personally appeared E. D. Scarth, well known to me to be a credible person, who, after being by me first duly sworn, did depose and say that he is duly authorized to make supplemental responses to the fore-going interrogatories on behalf of the TU Companies, that he has read the foregoing supplemental responses to said interroga-tories, and the same are true and correct, to the best of his knowledge and belief.
E.
D.
SCARTH SUBSCRIBED AND St40RN TO before me this //ed, day of March, 1980 to certify which witness my hand and seal of office.
hnijltJChk&
uotary fuelic, Dallas County, Texas P
My Commission Expires:
8-31-21 i
4