ML19309D293
| ML19309D293 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 03/11/1980 |
| From: | Slicker F TEXAS UTILITIES CO., WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | JUSTICE, DEPT. OF |
| References | |
| NUDOCS 8004100221 | |
| Download: ML19309D293 (3) | |
Text
,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER
- 52 NRC Docket Nos. 50-498A D
50-499A COMPANY, PUBLIC SERVICE BOARD OF SAN ANTONIO, OF,;no AUSTIN, CENTRAL POWER _'
l"j,(no LIGHT COMPANY
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(South Texas Proj ect, Maitggsy 11060P q 1 and 2) 43g gghtir.; & SMD TEXAS UTILITIES GENERATI.
nas P
s JRC Docket Nos. 50-445A COMPANY, et al.
(Comanche Peak Steam Elec2ri 50-446A
'4 Station, Units 1 and 2)
~:
FOURTH SUPPLE > ENTAL ANSWER OF TEXAS UTILITIES COMPANY AND ITS SUBSIDIARIES TO THE FIRST SET OF INTERROGATORIES AND REO,UESTS FOR PRODUCTION OF DOCUMENTS FROM DEPARTMENT OF JUSTICE COFE NOW TEXAS UTILITIES COMPANY ("TU"), TEXAS UTILITIES GENERATING COMPANY ("TUGC0"), DALLAS POWER & LIGHT COMPANY, ("DPL"),
TEXAS ELECTRIC SERVICE COMPANY ("TESC0"), and TEXAS POUER & LIGHT COMPANY ("TPL"), all collectively referred to as "TU Companies", in compliance with Section 2.740b and 2.741 of the Rules of Practice of the Nuclear Regulatory Commission ("NRC"), and make the follow-ing supplemental answers to the Department of Justice's First Set or Interrogatories.
The answers are in addition to answers given and documents produced in response to interrogatories and during depositions of employees of a Texas Utilities Company.
Sucolemental Response to Interrogatorv 1(c):
The City of Brownsville has recently been admitted to membership in TIS.
See the documents attached hereto.
Sunclemental Response to Interrogatory 16(b):
Mid-Tex Electric Cooperative and the City of Denton have recently explored their alternatives for power with TU.
See the documents attached hereto.
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8004100 h
GOGU I C M /
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.
20 j
,d&Mk v Frecerick K.
Slicker ATTORNEYS FOR TEXAS UTILITIES COMPAIPI, TEXAS UTILITIES GENERATING COMPANY, DALLAS POWER & LIGHT COMPANY, TEXAS ELECTRIC SERVICE COMPANY, AND TEXAS POWER & LIGHT COMPANY I
F THE STATE OF TE7AS 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 SWORN TO before me this
/ / d_ day of March, 1980 to certify which witness my hand and seal of office.
i n o s l& Obr Notary Puoite, Dallas County, Texas
~
My Commission Expires:
R'-3 l-2l l
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