ML19320C258
| ML19320C258 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/08/1980 |
| From: | Hudson T BAKER & BOTTS |
| To: | Buchorn P CITIZENS FOR EQUITABLE UTILITIES |
| References | |
| H-2480-760, NUDOCS 8007160553 | |
| Download: ML19320C258 (4) | |
Text
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(ff ESTED CORRESPONnF,NCF.
BAKER & BOTTS CNE SH ELL DLAZA houston, TEXAS 77oo2 L "
WASHINGTON OFFICE TELEX 76*2779 17C1 PEN N SYLVANIA AVE N. W.
T ELECO M M U NICATIO N wA5NINGTCN. 3. C 20004 (713) 229+lS23 NCUSTON TELEPwCNE (2C2) 457-55 0 0
{202)457-5536 WASMINGTON D.C.
H-2480-760 (ST'/ Application for Operating License) ti July 8, 1980 DOCKETED USNRC 3
g JUL 141980 >
Mrs. Peggy Buchorn Office ot tha Saareta1 4 Executive Director afh g
,,[
d citizens for Equitable Utilities, Inc.
Route 1, Box 432 Brazoria, Texas 77422
Dear Mrs. Buchorn:
The purpose of this letter is to identify for you those matters which, as we understand your deposition testi-many, you have agreed to produce for us within thirty days.
Those items are:
1.
On pages 73-75 of your deposition you agreed to give us the name of an individual who was an architact and who said that any foreign material in concrete materially affected its strength.
2.
On pages 75-76 of your deposition,'you agreed to furnish-us within two weeks the notes which you took concerning the conversation with the architect referenced above.
3.
On pages 76-77 of your deposition, you agreed to furnish us details concerning an alleged conversation con-cerning some purportedly qualified individual who assertedly had some question in his mind concerning t.he radiation resistant properties of the grout used to repair the voids in the reactor containment building.
4.
On pages 137-138 of your deposition, you have agreed to furnish documentation and specific page references to documents which you contend support your contention that the applicant has selected the wrong wind speed for design of the structures of the South Texas Project.
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GAKED & CoTTO 5.
On pages 144-145 of your deposition, you agreed to identify the relevant portions of the eight documents listed in answer to. interrogatory no. 4 which support your contention relating to wind speeds.
6.
On page 152 of your deposition, you agreed to identify for us the document which supports your contention that:
" buildings that can withstand winds of 60 m.p.h. may buckle under winds of 180 m.p.h. because the pressure on their surfaces has increased by a factor of 9".
7.
On page 157 of your deposition, you agreed to search your records and advise whether or not you had any documentary record recording the claimed conversation in which, it is asserted, that some unidentified person claiming to have authcritative knowledge told you that "...even a design strength of 70 lbs. per square foot (would be) null and void."
8.
On pages 180 and 181 of your deposition, you agrt2d to furnish a document which you state that you have in your files which quotes from the documents footnoted in contention no.
5.
9.
On pages 190 and 191 of your deposition, you are asked.to, but could not give us the name of some person who had been asked to research documents relating to the effect of humidity on the deposition rate of radionuclides (contantion no. 6).
At the close of your deposition, it was agreed that the names and other information you were to provide to us would be made available within 30 days of the deposition, i.e.,
July 17, and that the documents or relevant portion thereof would be made available for inspection in Bay City prior to the resumption of your deposition on August 5th.
(Tr. 207-8)
I would appreciate your advising us when the documents are located and available for inspection.
I suggest sometime during the week of July 28th.
1 CAKER & CoTT3 4
If you have any questions, please call on me.
Very truly yours, CRIGNAL. SIGNED BY THOMAS B. HUDSON, JR.
Thomas B. Hudson, Jr.
cc:
Mr. Charles Bechhoefer, Chairman Atomic Safety and Licensing Board
(/
(b U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8/
usNac
.y I
I4M>-
Dr. James C.
Lamb, III 313 Woodhaven Road 6-N b seengary Chapel Hill, North Carolina 27514 Ah 1
Dr. Emmeth A. Luebke
'""s Atomic Safety and Licensing Board
'~
U.S. Nuclear Regulatory Commission Washington, D.C. 20555
,Mr. Henry J. McGurren Hearing Attorney
)
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
Mr. Richard W.
Lowerre Assistant Attorney General for the State of Texas P. O.
Box 12548, Capitol Station Austin, Texas 78711 Hon. Burt O'Connell County Judge, Matagorda County Matagorda County Courthouse Bay City, Texas 77415 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 CAKER & Corr 3 Mr. Chase R. Stephens Docketing and Service Section office of the' Secretary of the Commission U.S. Nuclear. Regulatory Commission Washington, D.C. 20555 Mr. Jack Newman Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 Mr.
L. R. Jacobi Houston Lighting & Power Company Energy Development Complex Room B-372 Houston, Texas 77002 Mr. Lanny Sinkin Citizens Concerned About Nuclear Power, Inc.
116 Villita St.
~ San Antonio, Texas 78205 TBH:03:H -
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