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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
[Table view] Category:PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5901982-02-13013 February 1982 Motion for Postponement of All Action on CP Application Until Applicant States That Util Irrevocably Committed to Building Plant If CP Received.Certificate of Svc Encl ML20040H0761982-02-0909 February 1982 Motion for 30 Addl Days to File Proposed Findings of Fact & Conclusions of Law.Length of Record Necessitates Extension. Decision Would Not Be Delayed Since Addl Hearings to Be Held in Apr 1982 ML20040E2781982-01-29029 January 1982 Requests for Clarification Re R Alexander 811130 Petition to Intervene.J Silberg 820122 Ltr Indicates That Order Denying Petition Issued,But No Order Has Been Served.Certificate of Svc Encl ML20039B7481981-12-17017 December 1981 Response Opposing Tx Pirg 811207 Motions for Addl Testimony, Further Development of Record & Admission of New Contention. Motion Superficial Attempt to Delay Proceeding & Totally Devoid of Merit.Certificate of Svc Encl ML20062M6441981-12-14014 December 1981 Response Opposing Doherty 811015 Renewed Motion for Addl Evidence on Tx Pirg Contention 31.Doherty Failed to Comply W/Aslb 811110 Order.Motion Is W/O Merit & Would Cause Unnecessary Delay.Certificate of Svc Encl ML20062M6241981-12-0707 December 1981 Motion for Tx Pirg to Present Addl Evidence,To Order Applicant to Serve Tx Pirg W/Quadrex Rept & to Rule That Need for Power Is Tx Pirg Contention.Alternatively,Requests Admittance as Tx Pirg Contention.W/Certificate of Svc ML20039B0771981-12-0707 December 1981 Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31 Re Applicant Technical Qualifications.Specifies Portions of Quadrex Rept,Indicating Organizational Changes That Should Be Made.Certificate of Svc Encl ML20038A8841981-11-20020 November 1981 Response Opposing Doherty 811106 Motion for Addl Testimony on Need for Power.Pleading Construed as Motion to Reopen Record.Burden of Explaining Why ASLB Would Reach Different Result Not Met.W/Certificate of Svc.Related Correspondence ML20010F4791981-09-0303 September 1981 Response Opposing Further Consideration of Radon Releases. NRC Analysis of Radon Releases in Final Suppl to Fes Satisfies NEPA Requirements,Complies W/Commission 780414 Order & Supplies Sufficient Info.Certificate of Svc Encl ML20010G1101981-09-0303 September 1981 Response to ASLB Request Re Positions on ALAB-640.Radon Emissions Determined by ALAB-640 Constitute Significant Addl Environ Impact.Certificate of Svc Encl ML20010A1171981-08-0505 August 1981 Motion to Strike Marrack Prefiled Testimony.Testimony Is Not Specifically Responsive to F Sanders 810205-06 Testimony. Certificate of Svc Encl.Related Correspondence ML20009B2031981-07-0707 July 1981 Response in Opposition to Intervenor Doherty 810622 Request for Leave to File Contention 57.No Good Cause Shown for Late Filing & No Specificity Provided.W/Science News Article & Certificate of Svc ML20005B3801981-06-22022 June 1981 Request for Leave to File & Submission of Contention 57 Re Vulnerability of Control Sys to Electromagnetic Pulses. Issue Has Not Been Made Public Until Recently.W/Certificate of Svc ML19347F4941981-05-0808 May 1981 Reply Opposing Doherty 810423 Filing Re Contention 56, If Filing Is Motion to Add Late Filed Contention. Contention Refs Alleged Problem at Browns Ferry Which Is Not Applicable to Mark III Containments.W/Certificate of Svc ML19347F4661981-05-0808 May 1981 Response Opposing Doherty 810423 Motion to Reopen Record on Need for Power Contention.Aslb Should Issue Order That Motion Is Moot & Direct Applicant to Update Testimony on Need for Power Testimony Later.Certificate of Svc Encl ML20003H9551981-04-29029 April 1981 Motion for Order Adopting Specific Procedures to Govern Conduct of cross-examination During Health & Safety Phase of Proceeding.Procedures Will Ensure cross-examination Not Cumulative.W/Proposed Order & Certificate of Svc ML19343D3891981-04-27027 April 1981 Motion to Strike I Bross 810331 Affidavit.Affidavit Does Not Respond to Ld Hamilton Supplemental Affidavits But Constitutes Personal Attack of Affiant.Certificate of Svc Encl.Related Correspondence ML20126J9451981-04-24024 April 1981 Motion Opposing Applicant 810422 Motion to Preclude Jm Scott Testimony.Tx Pirg & Intervenor Doherty Are Separate Parties ML20003H7981981-04-22022 April 1981 Motion for Addl Testimony & cross-examination on Conservation Techniques,Interconnection & Effects of Const Delay.Proceedings Have Not Addressed These Issues. Certificate of Svc Encl ML20003H7471981-04-22022 April 1981 Motion to Preclude Jm Scott Testimony.Intent of ASLB 810407 Order Was to Preclude Scott from Having Dual Role of Atty & Witness for Any Other Party.Certificate of Svc Encl. Related Correspondence ML20126H9601981-04-0707 April 1981 Request for Order Directing Util to Reissue 810331 Pleading W/Correct Title.Defective Title Did Not Put All Parties on Notice ML20126H9641981-04-0707 April 1981 Response in Opposition to Util & NRC 810330 Motions to Disqualify Tx Pirg Counsel,Jm Scott.Counsel Will Appear as Expert Witness.Public Interest Requires Counsel Presence. Certificate of Svc Encl ML19347D9721981-03-31031 March 1981 Response to NRC & Applicant Responses to J Doherty 810222 Motion for Reconsideration of Admission of Contention 21. Filing of Motion Was Timely Under Circumstances. Certificate of Svc Encl ML19345G4941981-03-30030 March 1981 Brief,In Form of Pleading,Addressing Need to Disqualify Tx Pirg Counsel Per Disciplinary Rules 5-101 & 5-102.Having Chosen to Appear as Witness,Scott Should Be Barred from Participation as Atty.Certificate of Svc Encl ML19345G5831981-03-24024 March 1981 Response for Order Allowing Intervenors to File Id Bross Supplemental Affidavit to Respond to Ld Hamilton Affidavit on Behalf of Util.One Day Delay Should Be Excused Due to Intervenor Attempt to Comply W/Rules.W/Certificate of Svc ML20003D2161981-03-0404 March 1981 Response Opposing Tx Pirg 810217 Motions on Procedural Matters,Referral of Interlocutory Appeal,Certification of Various Issues & Removal of Aslb.Motion Contains Misrepresentations of Alab Rulings.W/Certificate of Svc ML19341D4801981-02-25025 February 1981 Response to Intervenor Doherty Third Supplemental Response to Motion for Summary Disposition.Intervenor Has No Right to File Late Responses,Shows No Good Cause & Info Has No Relationship to Affected Contentions.W/Certificate of Svc ML20003C3161981-02-17017 February 1981 Requests to ASLB for Interlocutory Appeal & Certification of Questions & to ASLAP for Direct Certification of Question Re Ability of Intervenors to cross-examine Witnesses. Certificate of Svc Encl ML20003B0771981-02-0505 February 1981 Response in Opposition to Intervenor Jf Doherty Contention 55.Contention Does Not Address 10CFR2.714 Requirements & No Good Cause Established for Late Filing.Certificate of Svc Encl ML19345E8521981-01-30030 January 1981 Suppl to 810129 Motion Requesting Reversal of 810123 Ruling Denying Intervenor Rentfro cross-examination Opportunity.Evidence Supporting Intervenor Discernible Interest in Issues Outlined.W/Certificate of Svc ML19345E5721981-01-29029 January 1981 Requests ASLB Reconsider Ruling Restricting cross-examination,for Interlocutory Appeal & Certification of Questions.Also Moves Aslab for Directed Certification of Questions & Appointment of New Aslb.W/Certificate of Svc ML19341B6021981-01-29029 January 1981 Response Opposing Intervenor Doherty 810123 Motion to Change Cross Examination Procedures.Repetitious cross- Examination Would Be Avoided If All Intervenors Attended All Proceedings.Certificate of Svc Encl 1982-07-02
[Table view] |
Text
, 12 July 1980 UNITED STATES OF AIERICA =
NUCLEAR REGULATORY C0?SIISSION 4 y
T BEFORE THE ATOLIIC SAFETY AND LICENSIt!G BOADD %
In the I.:atter of I b
C N.f l
- 8Q7 g i L HOUSTON LIGHTItiG & POWER I 4 e
COITANY ,
I Docket No. 50-466 g I
(AllensCbeekNuclear i Generating Station, ! ,
Unit M0. 1) i Intervenors, 't!.
Rerfro & D. I.iarrack, Response to Anolicant's 'Pyh for Denial of Intervenor's TCotion to Connel of 11 June 1980 4/
The Applicant's claim of 26 June 1980 that these Intervenors did not make proper service of the InterrogatoriesiRequest for Documents served on them 3 May 1980 and the subseque$t IJotion to Compel of 16 June 1980,is incorrect and simply reflects confusion and/or lack of communication between the Applicant's several groups of attorneys.
The Interrogatories & Request for Documents and subsequent Motion viere duly and properly served on the Applicant's declared lead-attorney, I*r. R. Gordon Gooch of Baker & Botts, 1701 Pennsylvania Avenue, Washington, D.C.
That Mr. Gooch is the Applicant's Lead Attorney is shown by:-
A) Mr. Gooch was introduced as the Applicant's Lead Attorney at the Pre-Hearing Conference in Houston 17 November 1978.
B) That on the NRC's Service List, I*r. Gooch's name precedes that of Ifx. Copeland and I.:r. Nevnnan as it should if Mr. Gooch is indeed the Lead Attorney for the Applicant.
(See Attachment A from ):ay . 1980 signed by I/x. Sohinki) .
Clearly, Gooch before Coneland in this,and other, service lists are not names in a random order, or alphabetical.
SeeFootnote.p WS th
, 8 0 07 2 2 0 SSA
-Pago 2-C) This Intervenor has racoived no advisory updating the status' of Lead-Attorney for the Applicant or requesting other persons be served in this matter.
- The Applicant's claim that the Interrogat' ries & Request for Docu-ments s(qt to Ne Applicant was untimely is a misrepresentation.
Intervenor, Dr. Marrack, accepted consolidation of his contention 2ir with that of Mr. Rerrro on the explicit understanding that Dr'.
Carrack's rights to Discovery were preserved. This condition was restated in Dr. Marrack's letter served on tir. Hancock on 2 May 1980 in response to Mr. Hancock's letter of 18 April 1980. (See Attach-ments L & D).
Neither the Applicant nor the HRC Staff Attorneys raised timely objection to preservation of Dr. Marrack's due right to Discovery.
Thus Dr. Marrack's Interrogatories & Request for Documents submitted through Mr. Rentrro were in order, proper and timely.
For the above reasons and others, Mr. Renfro and Dr. Marrack request that their Motion to Compel be sustained and that Applicant be ordered to respond.
1/ It can be anticipated that the Applicant will argue in a similar manner that Dr. Marrack's Interrogatories & Request for Documents of 11' June 1980 was not properly served. (The Applicant has not responded to these to date). For the above shown reasons, Dr. Marrack contends that the service of 11 June 1980 on the Applicant was timely and correct.
It is therefore moved that in the interests of orderly business, you so advise the Applicant.
Respectfully submitted dgjtopi. (v . Ms~-m
. f'p. W. RenlEro '
D. r'. arrack P.O. Box 1335 a20 Mulberry Lane 12 : July 1980 Rosenberg, Texas 77471 Bellaire, Texas 77401
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYAtl0LICENSINGBOARD y w s
In the Matter of -
6 Ucn3c HOUST0ft LIGHTIllG & POWER COMPANY Docket No. 50-466 i
_ JCL f 7 g 3 -
L (Allens Creek Nuclear Generating ) Oneof Dd.en tisggg dJ Station, Unit 1) ) y erex3 s CERTIFICATE OF SERVICE 2 ;id \
I hereby certify that copies of "NRC STAFF'S RESPONSE TO MOTION TO CONFIPJi AGREEMENTS ON CONSOLIDATION AND TO CONSOLIDATE CERTAIN CONTENTIONS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 20th day of May,1980:
Sheldon J. Wolfe, Esq. , Chairman
Atomic Safety and Licensing Board Panel Asst. Attorney General. for the U.S. Nuclear Regulatory Commission State of Texas Washington, DC 20555 P.O. Box 12548 Capitol Station Dr. E. Leonard Cheatum Austin, Texas 78711 Route 3, Box SF"A Watkinsville, scorgia 30677 Hon. Jerry Sliva, Mayor
~
City of Wallis, Texas 77485 Mr. Gustave A. Linenberger
- Atomic Safety and Licensing Board Panel Hon. John R. Mikeska U.S. Nuclear Regulatory Commission Austin County Judge Washington, DC 20S55 P.O. Box 310 Bellville, Texas 77418 R. Gordon Gooch, Esq.
Baker & Botts Mr. John F. Doherty 1701 Pennsylvania Avenue, N.W. 4327 Alconbury Street Washington, DC 20006 Houston, Texas 77021 J. Gregory Copeland, Esq. Mr. and Mrs. Robert S. Framson Baker & Botts 4822 Waynesboro Drive One Shell Plaza Houston, Texas 77035 Houston, Texas 77002
- Mr. F. H. Potthoff, III Jack Newman, Esq. 1814 Pine. Village Lowenstein, Reis, Newman & Axelrad Houston, Texas 77080 1025 Connecticut Avenue, N.W.
Washington, DC 20037 D. Marrack 420 Mulberry Lane Carro Hinderstein Bellaire, Texas 77401 8739 Link Terrace Houston, Texas 77025 .. .
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's 420 Mulberry 1Ana Bellaire, Texas 77401 p [/
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May 2, 1980 -
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Darrell Hancock' --
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Attorney.for Houston '
D* ' "
lighting and Power N c/o Baker and Botts One shell j'laza f$ ,'y ._ i 7 j; I >u)
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Houston, Texas 77002 g-Q
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Wayne E. Rentfro .
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P.O. Box 1335 ,
Rosenberg, Texas 7747J. s lll? '
4entlemen:
In response to your letter of 18th April,1580 sqy understanding is as follows; _
A) Se substance oI my contention (2b) is consolidated with Mr.Rentfro's contention (2) Two.
B) It is proposed that Mr. Rentfro be designate, by agreement between ourselves, as the " leading party" in this contention.
C) he 120 day lir:it for ' discovery' that initiated upon the acceptance of g contention (2b) in the ' order 11 March,1980 is unaffected by this proposed consolidation of zny centention (2b) with Mr. Rentfro's contention (2) or by he being designated as the ' leading party' for our consolidated contentions except to the extent that Mr. Rentfro will submit my requests.
D) All correspondence, orders or other cor=unications shall be sent to both Mr. Rentfro and myself at our respective addresses.
If this is not your ' understanding please advise Mr. Rentfro and qself within 7 days of receipt of this letter. ,
Yours respectfully, .
sce v Ih d Marrack Intervenor Df/ms CC Mr. Rentfro O
e
BAKER & BOTTS CNE ENEu. PLAZA /
{
. Houston, TEXAS 770o2 '
wASNtNOTON OFFICc TELEX 76 2779 1700 PEN N SWLVANIA AVE..N w. TELECON NU NICATlO N WASHINCTON. O C. 20006 (7t3) 229-4523 NOU STO4 TELEPHON E (202) 4S7- 5500 (202)457-5538W ASHINGrom. D. C. '
H-2412-701C-2 , April 18, 1980 Houston Lighting & Power Co. -
(AC Lic.ensing Hearing) h .
. s
'ECCKETED Mr. D. Marrack % t!SNac
,1 \
420 Mulberry Lane -
6 _
Bellaire, Texas 77401 ; JULi 71980 > -,
" 02ce of the Sacrehry 'k Mr. Wayne E. Rentfro 9 Dociat!ng & Mee P. O. Box 1335 Branc'i y
Rosenberg, Texas 77471 Gentlemen:
. This is to confirm my understanding, based on a telephone conversation with Mr. Rentfro on April 15, 1980, that pursuant to our letter of March 26, 1980, you have agreed between yourselves that lir Rentfro will serve as leading party for purposes of discovery, presentation of witnesses, cross-exhmination, etc., on your consolidated conte. tion on the health effects of high-voltage trans-mission lines.
If my understanding on this matter is inaccurate in any way, p1' ease advise me promptly.
Thank you for your help in taking cars of titi"s'. ,,.'.'.
organizational matter. ' P~~
Yours very truly, -
4LLMIA. M DH: 108 Darrell Hancock Attorney for Houston Ligh. ting
& Power Company cc: All Parties l .: .. .
ws m
.e , , , UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION
. . BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD ,
Ns
/. \
,, /? ::oc:E r4D Us:G.C In the Matter of $ i-5
'- '! .. 4 " $.][} p L-
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HOUSTON LIGHTING'& POWER 5 3 e,c C COMPANY S Dockcu No. 50-466 M.'h.E,L.m
$ Q,'% '" ^,nd 9 (Allens Creek Nuclear S
<( '
/6!t\Uy
' Generating _ Station, Unit S No. f) $
CERTIFICATE OF SERVICE pp I hereby certify that copies of the foregoir.g were served on the following by deposit in the United
. mail, postage, prepaid, or by hand-delivery. , gp ,y 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 Res,ulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Teyas 78711 Dr. E. Leonard Cheat.:=
Route 3. Box 350A Watkinsville, Georgia 30677 Stephen A. Doggett, Esq.
P. O. Box 592 Mr. Gustave A. Linenberger Rosenberg, Texas 77471 Atomic Safety and Licensing Board Panel Mr. John F. Doherty U.S. Nuclear Regule. tory Commission 4327 Alconbury Washington, D. C. 20555 Houston, Texas 77021 1 Mr. Chase R. Stenhens Robert S. Framson i Docketing and Se'rvice Section Madeline Bass Framson Office of the Secretary of the 4822 Waynesboro ;
Commission Houston, Texas 77035 l U.S. Nuclear Regulatory Commission I Washington, D. C. 20555 Carro Hinde2.L*:ein ,
J. Gregory Copciand 8739 Lin.4 T2crace 1 3000 One Shell Plaza Houston, Texas 77025 Homiton, Texas 7 ~/002 Atomic Safety and Licensing Ms. Brenda McCorkle Appeal Board 6140 Darnell U.S. Nuclear Regulatory Houston, Texas 77074 Commission Washington, D. C. 20555 Mr. W. Matthew Perrenod l 4070 Merrick 1 Jack Neviman, Esq. Houston, Texas 77025 l 1.ortenstein, Reis. Neman & Axelrad l 1025 Connecticut Avenue, N.H. Mr. Wayne E. Rentfro Hashington, D. C. 20037 P. O. Box 1335 Posenba.rg, Taxas 77471 Steve Sohinki, Esq.
Staff Counsel Mr. James M. Scott U.S. Nuclear Regulatory Commission 13935 Ivy Mount Washington, D. C. 20555 Sugar Land, Texas 774,78
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