ML19318B936

Response in Opposition to Jm & M Bishop Interrogatories 1a, 1b,2a,2b,2c,2d & 2e & Requests for Production of Documents. Urges Restriction of Questions to Contentions Still Subj to Discovery.Certificate of Svc Encl

ML19318B936
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	06/24/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8006300307
Download: ML19318B936 (5)

Text

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UNITED STATES OF AMERICA p004 6 NUCLEAR RT1ULATORY COMMISSION [ UCO 9] BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -{ aua anw80 " '~t

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                                                           'U, 0xatbg & trdca In the Matter of                      S S

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                                                                         '43 HOUSTON LIGHTING & POWER COMPANY      S   Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S APPLICANT'S RESPONSE TO INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM J. MORGAN BISHOP AND MARGARET BISHOP In response to the interrogatories and requests for production of documents propounded by J. Morgan Bishop and Margaret Bishop, Houston Lighting & Power Company (Applicant) answers as follows: INTERROGATORY NO. la: Identify each witness, other than an expert witness, who Applicant may call in this proceeding, and provide a summary of the testimony which each such wit-ness is expected to offer. INTERROGATORY NO. lb: Identify all documents upon which each such witness may rely in any way, and provide copies of any such documents. INTERROGATORY NO. 2a: Identify each expert witness who Applicant expects to call in this proceeding. INTERROGATORY NO. 2b: State the gi.alifications and creden-tials of each such expert witness. INTERROGATORY NO. 2c: Provide a summary of the testimony which each such witness is expected to offer. INTERROGATORY NO. 2d: State the factual basis for each con-clusion or opinion each such witness expects to present or j draw in such expert's testimony.  ! l

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INTERROGATORY NO. 2e: Identify all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon by such expert in formulating the expert's opinions and conclusions, including workpapers, preliminary outlines and memoranda, and communications be-tween such expert and Applicant. Provide copies of any such documents. ANSWER: Applicant objects to each of these interrogatories on the grounds that they are untimely, overly broad and burdensome. At this time, there are approximately 80 con-tentions in this proceeding and these interrogatories appear to inquire into each contention in the proceeding without limitation to the contentions upon which you have been designated as the lead party for purposes of discovery. Given the broad scope of such interrogatories, they are clearly improper because they seek to inquiry into con-tentions upon which discovery has terminated and upon which Applicant has previously answered all expert interrogatory questions propounded by the party responsible for conducting discovery on such contentions. If Intervenors Bishops will reformulate their interrogatories restricting them to con-tentions which are still subject to discovery and for which they are the lead party for purposes of discovery, Applicant will attempt to answer their interrogatories. j l 1 i

Respectfully submitted, OF COUNSEL: J Gregorg C elagd Thoma# B' die, Jr. BAKER & BOTTS arles G. Thrash, Jr. 3000 One Shell Plaza 000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W. Washington, D. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S (Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Response to Interrogatories and Requests for Production of Documents from J. Morgan Bishop and Margaret Bishop in the above-captioned proceeding were. served on the following by deposit in the United States mail, aostage prepaid, or by hand-delivery this J fd( day of J244vt , 1980. Sheldon J. Wolfe, Esq., Chairman Richar 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 Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek 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 J dge, 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 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory 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 Mr. J. Morgan Bishop Stephen A. Doggett, Esq. 11418 Oak Spring P. O. Box 592 Houston, Texas 77043 Rosenberg, Texas 77471 Mr. John F. Doherty Robert S. Framson 4327 Alconbury Madeline Bass Framson Houston, Texas 77021 022 Waynesboro Ho ston, Texas 77035 Ms. Brenda McCorkle 0140 Carnell Mr. W. Matthew Perrenod Houston, Texas 77074 4070 Merrick Houston, Texas 77025 Mr. Wayne E. Rentfro P. O. Box 1335 Mr. James M. Scott Rosenberg, Texas 77471 13935 Ivy Mount Sugar Land, Texas 77478 Mr. F. H. Potthoff 7200 Shady villa,fio. 110 Houston, Texas 77080

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