ML19309F323
| ML19309F323 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 04/25/1980 |
| From: | Blume M, Chanania F, Hodgdon A NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8004290227 | |
| Download: ML19309F323 (3) | |
Text
800.4290227 M
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UNITED STATES g#(/[ g NUCLEAR REGULATORY COMMISSION
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April 25, 1980 fiarshall E. Miller, Esq., Chaiman Sheldon J. Wolfe, Esq.
Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 l
Michael L. Glaser, Esq.
1150 Seventeenth Street, N. W.
l Washington, D. C.
20036 Re: Houston Lighting & Power Company, et al.
South Texas Project, Unit Nos. 1 & 2, NRC Dkt. 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 participatei in the depositions of the following persons:
Frederick John Meyer, He-bert '.i.
Woodson, Aubrey D. Sprawls, Aubrey M. Smith, James W. Atkins, Norman Lerner, Joseph E. Bondurant and Glenn W. Stagg.
The deposition of Robert Hartley, Staff's designated expert engineering wit-ness, was originally postponed until April 24-25, 1980, and has now been deferred, by agreement of counsel, to permit settlement efforts to continue without interruption.
On March 20, the Staff filed its response in opposition to the petitions of Houston Lighting and Power Co., Texas Utilities Generating Co. and Central and South West Companies filed before the Atomic Safety and Licensing Appeal l
Board for directed certification and reversal of the Licensing Board Order of March 7,1980 ordering production of certain settlement documents. The Staff participated in oral argument before the Appeal Board on Ibrch 27, and filed two memoranda, on April 4 and April 9, in response to the Appeal Board's post argument Order of March 28, 1980.
By Order of April 2, the Appeal Board sought the views of the parties on Brownsville's Motion for Leave to File an Affidavit ac Amicus Curiae.
Pursuant to that Order, the Staff filed its views on April 9,1980.
On April 2,1980, the Staff joined with CSW, HL&P, TUGCO, City of Austin, City Public Service Board of San Antonio, South Texas Electric Cooperative, Ifedina Electric Cooperative and Tex-La Electric Cooperative of Texas, Inc.
in moving this Board for a 30-day extension of procedural dates, which was granted after an expedited oral argument.
In addition, the Staff has taken the following actions as regards discovery since filing its last report:
a)
On !! arch 11, 1980, Staff filed a motion to quash the subpoena of Mr. Rodney Frame and a response to HL&P's motion to compel further production by the NRC Staff and its expert economic witness.
b)
On March 14, 1980, Staff filed a Motion to Compel Supple-mental Responses by HL&P.
On March 31, the Board ordered production (under a Protective Order attached to the Order) of the documents identified in Part II of the Motion and denied as moot the request for documents in Part I on HL&P's representation that the documents sought had been produced previously.
Staff then informed HL&P's counsel by letter that Staff had no record of having received the documents in Part I.
Although HL&P counsel has agreed to produce the documents, Staff has not yet received them.
As regards the documents in Part II, Staff informally agreed to forward a signed stipulation in order to mitigate any concerns regarding revelation of HL&P proprietary information.
Staff has subse-l quently received one of the documents covered by the stipulation.
l i
c)
On March 17, 1980, the Staff filed its views on consolidation i
pursuant to the Board's directive at the March 7th prehearing l
conference.
d)
On March 26, 1980, the Staff and the Department of Justice filed a Joint Response to riL&P's Motion to Quash the Subpoena of fir. Glenn W. Stagg. HL&P's motion followed the joint application of the Staff and the Department for a subpoena directed at Mr. Stagg, filed on March 14, 1980.
e)
On April 1, 1980, the Staff provided an updated response to HL&P's Second Set of Interrogatories and TV's First Set of Interrogatories.
f)
On April 16, Staff made its designated expert engineering wit-ness' documents available in Phoenix, Arizona, for HL&P and TV's inspection.
The Staff has also informally produced documents to and received documents from HL&P and TV.
Respectfully submitted, L a s p. L.. a Fredric D. Chanania Counsel for NRC Staff
,i f W Michael B. Blume Counsel for NRC Staff
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Ann P. Hodgdon Counsel for NRC Staff cc:
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