ML19318A901

Second Set of Interrogatories & Requests for Production of Documents.Requests Identification of Documents Supporting Contentions & Identity of Persons Consulted in Preparing Contentions.Certificate of Svc Encl

ML19318A901
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	06/20/1980
From:	Hancock D, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Marrack D MARRACK, D.
References
NUDOCS 8006240341
Download: ML19318A901 (6)

Text

e

-2L/,fg/ ~

2.._13 g )

JUtl3;31980 > f lu.w.

32 '~

,7 /

JUNE 20,i 1980' f UNITED STATES OF AMERICA

' NUCLEAR REGULATORY COMMISSION we __

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5 5

HOUSTON LIGHTING & POWER 5 COMPANY 5 Docket No. 50-466 5

(Allens-Creek Nuclear 5 Generating Station, Unit 5 No. 1) 5 SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING & POWER COMPANY TO D. MARRACK Preface Pursuant to Sections 2.740b and 2.741 of the Commission's Rules of Practice, Houston Lighting & Power l

Company propounds the following Interrogatories and Requests I l

for Production of Documents to D. Marrack. Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person or persons making them no later than fourteen (14) days after service of these Inter-rogatories and Requests for Production, and each document requested should be produced no later than thirty (30) days after service of these Interrogatories and Requests for Production.

80062403gl

Interrogatories

, 1. List by title, date, author, publication, I

page and any other means of identification, every document that:

a. Supports your contention that neither the FES nor the FSFES addresses the impact upon migratory waterfowl along the transmission routes beyond the plant site, nor considers that this impact could be minimized by constructing the power lines to follow the Brazos River to the south of the site, then east and then north to the O'Brien substation; or

b. Supports the proposition that migratory waterfowl will or may strike the transmission line along Houston Lighting and Power Company's planned route from Allens Creek Nuclear Generating Station to the O'Brien substation.

As used in this interrogatory, the word " document" means and includes every writing or record of any type and description, including, but not limited to, correspondence, memoranda, stenographic or handwritten notes, drafts, studies, publications, invoices, ledgers, journals, books, records, accounts, pamphlets, voice recordings, reports, surveys, statistical compilations, work papers, data processing cards, computer tapes or printouts, or any other writing or ,.

recording of any kind.

2. List the name, address, telephone number, and technical qualifications of each person you have consulted in any way--whether successfully or unsuccessfully, and whether in person, by correspondence, by telephone, or by

, any other means--in conceiving, drafting, or otherwise preparing all or any part of your contention 2(c), or in requesting, obtaining, compiling, examining, studying, analyzing, or otherwise seeking or compiling evidence in support of all or any part of your contention 2(c).

3. List by title, date, publication, page, and any other means of identification every note, paper, document, article, book, or other writing or record, whether published or unpublished, written or prepared by you on the subject of migratory waterfowl or on the subject of electrical transmission lines or on both subjects.

Requests for Production of Documents

1. Produce and make available for copying every document listed in answer to Interrogatory No. 1(a) and 1(b), above.

2. Produce and make available for copying every note, piece of correspondence, and similar written or recorded information related to any consultation between you and any person listed in answer to Interrogatory No. 2, above and related in any way to the subject matter of your contention 2(c).

3. Produce and make available for copying every note, paper, document, article, book, or other writing or record listed in answer to Interrogatory No. 3, above.

Respectfully submitted, OF COUNSEL:

hMGregory hCopeland J.

6 C C. Thomas Biddle, Jr.

BAKER & BOTTS Darrell Hancock 3000 One Shell Plaza Charles G. Thrash, Jr.

Houston, Texas 77002 3000 One Shell Plaza Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Avenue, N.W. David Raskin Washington, D.C. 20036 Washington, D.C.

ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY

~

I l

i l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5 5

HOUSTON LIGHTING & POWER 5 COMPANY 5 Docket No. 50-466 5

(Allens Creek. Nuclear 5 Generating Station, Unit 5 Nc. 1) 5 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing First Set of Interrogatories and Requests for Production of

-Documents from Houston Lighting & Power Company to D. Marrack in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 20th day of June, 1980.

Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Dr. E. Leonard Cheatum I Route 3, Box 350A Hon. Charles J. Dusek l Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Mr. Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory

. U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555

R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 Steve Schinki, Esq. Carro Hinderstein Staff Counsel 609 Fannin, Suite 521 U.S. Nuclear Regulatory Commission Houston, Texas 77002 Washington, D. C. 20555 D. Marrack Mr. Bryan L. Baker 420 Mulberry Lane 1118 Montrose Bellaire, Texas' 77401 Houston, Texas 77019 Ms. Brenda McCorkle Mr. J. Morgan Bishop 6140 Darnell 11418 Oak Spring Houston, Texas 77074 Houston, Texas 77043 Mr. W. Matthew Perrenod Stephen A. Doggett, Esq. 4070 Merrick P. O. Box 592 Houston, Texas 77025 Rosenberg, Texas 77471 Mr. Wayne E. Rentfro Mr. John F. Doherty P. O. Box 1335 4327 Alconbury Rosenberg, Texas 77471 Houston, Texas 77021 Mr. James M. Scott Robert S. Framson 13935 Ivy Mount Madeline Bass Framson Sugarland, Texas 77478 4822 Waynesboro Houston, Texas 77035 . F. H. Potthoff 7200 Shady Villa, No. 110 Houston, Texas 77080 M%

Darrell Hancock DH-03-F