ML19323A568
| ML19323A568 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 03/27/1980 |
| From: | Franklin W LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Glaser M, Mark Miller, Wolfe S Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19323A569 | List: |
| References | |
| NUDOCS 8004210386 | |
| Download: ML19323A568 (1) | |
Text
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DOCKET NUM3ER PROD.& UTIL FACES *.NS ASkid DOCKET NUMBER PROD,^& UTIL FACN.kN C ' ' '
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L AW OFFICES LoWENSTEIN, NEWMAN, RErs, AxELRAD & TOLL 103 5 CJo' A CCTICUT AVENU E, N. W.
no@ tat LowEmstein WAS HINGTON. D.C. so 03.
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March 27, 1980 ALGER? w. C ARR, JR.
AmseC w. COTTeasoasaas "o'[c'e'r'.'e ^eu*6[
n FETER G. FLY.e CCCKETED
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Marshall E. Miller, Esquire J/
usnno Michael L. Glaser, Esquire
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Sheldon J. Wolfe, Esquire MAR 2 71980 >
Atomic Safety and Licensing Board 6'
Office of the Secretuy
}
j U.S. Nuclear Regulatory Commission Docketing & Service Bach Washington, D.C.
20555 g
j RE:
Houston Lighting and Power Company N
O 4
South Texas Project, Units 1 and 2 j
(Docket Nos. 50-498A and 50-499A)
Gentlemen:
Today Houston Lighting & Power Company files motions to compel production of specific documents from Mr. Robert H. Hartley and from Dr. Norman C. Lernor, the NRC Staff's two designated expert witnesses.
Copies of both motions are enclosed for each of you, and copies have been hand-delivered to the NRC Staff.
4 Depositions for both Mr. Hartley and Dr. Lerner are scheduled in the near future.
Houston received definitive j
word that the Staff would not produce Dr. Lerner's docu-ments in the course of document production yesterday.
The Staff has yet to respond to Houston's informal requests for Mr. Hartley's documents, and so Houston files its motion
]
to obtain a prompt resolution of this dispute.
Dr. Lerner is scheduled to be deposed on April 1 and 2, and as to his documents Houston requests a conference call on March 31.
Mr. Hartley is scheduled to be deposed 1
on April 7 and 8, and with respect to his documents a conference call anytime during the week of March 31 would be timely.
Houston will work with you and the Staff to make all necessary arrangements for these calls.
Respectfully submitted,
'e[
4 I
William J. Franklin Counsel for Houston Lighting
& Power Company Enclosures 800.4210386
.