ML19323F914
| ML19323F914 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 04/21/1980 |
| From: | Cowan F BAKER & BOTTS |
| To: | Buchorn P CITIZENS FOR EQUITABLE UTILITIES |
| References | |
| NUDOCS 8005290633 | |
| Download: ML19323F914 (4) | |
Text
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- J* / /18 1701 PC N NSYLVANI A AVE, N W T EL CCO M MU NICATION WA$HINGTON. O C 20006 (713) 229-4523 HOUSTON T CLC PHON C (202) d 5 7 - 550 0 (204 457 5L36 WASHINGTON. D. C.
April 21, 1980 N
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00CKETED Mrs. Peggy Buchorn jg, USNHC j\\
Executive Director APR 4
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Citizens for Equitable j
3 Utilities W
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Route 1, Box 432 keing a 3eng Brazoria, Texas 77422 DCL-
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Dear Mrs. Buchorn:
This will serve to confirm and notify all interested parties of our telephone conversation of Thursday, April 17 in which you and I discussed, (with Mr. Biddle on the telephone) a number of matters of mutual concern.
I confirmed to you that we were attempting to obtain as expeditiously as possible a copy of the Quality Assurance Procedure 2.6.
Mr. Rodgers and Mr. Jacobi are ob-taining a copy of this document for you and will endeavor to deliver it to you as expeditiously as possible.
If some human error occurs and this does not take place, please let me know as rapidly as possible.
';c also discussed the desirability of obtaining an extension of the discovery period.
I told you that Mr. Sinkin and I had discussed this and he and I both agreed that an extension of the discovery period would be mutually beneficial.
While I did not discuss with Mr. Sinkin the exact date to which the discovery period should be extended, it is my current idea l
that we should request the Board to extend time until August 31 l
since a hearing in the fall is the earliest date which has been l
suggested.
Mr. Sinkin has indicated that he agrees wholeheartedly l
that the discovery period should be extended and I believe that l
I accurately perceive that he would have no objection to the August 31 extension.
He is receiving a copy of this letter and if he has any disagreement with this, I would appreciate his advising us as soon as possible.
8006290633 g
1
4 bAKCH & 00TTS r
o Ms. Peggy Buchorn Page 2 April 21, 1980 My understanding from our conversation of the 17th is that you agree that the discovery period should be extended and have no objection to and in fact join in a request that the discovery period be extended until August 31.
Mr. Jack Newman is actually preparing this Motion and it will be pre-pared and filed, as I understand our schedule, sometime next week, that is sometime during the week of April 21.
I also advised you that you would be receiving very soon a letter dated April 18, 1980 to Mr. Swayze concerning the taking of his deposition.
I also advised you that Mr. Sinkin's deposition cur-rently scheduled for May 14, 1980 at 10:30 a.m.
in Mr. Sinkin's office in San Antonio.
I indicated to you that you were of course welcome to attend Mr. Sinkin's deposition but not re-quired to do so.
You indicated to me that it would be necessary for you to check your schedule and determine whether you would be available to attend Mr. Sinkin's deposition.
I also indicated to you that, if it was consistent with your commitments, we.would very much like to take your deposition the following day.
The purpose of your deposition, like that of Mr. Swayze's and Mr. Sinkin's, is to endeavor to make certain that the Nuclear Regulatory Commission, Brown & Root and the Houston. Lighting & Power Company have every scrap of information in your possession or subject to your control relating in any way to the actual or arguable safety deficiencies, if any, in the South Texas Project.
We believe that the formalities of a deposition procedure, including the administration of an oath, will be helpful in this connection.
As indicated in our letter to Mr. Swayze, we are per-fectly happy to make available to you during or prior to the taking of your deposition any documents which will be helpful in refreshing or documenting your recollection'.br enabling you to testify fully concerning any facts which you have in your possession.
We will also expect you to produce all documentation of any type which refreshes or supports your recollection and perception of the facts.
Assuming that the. Commission agrees to extend the discovery period, we understand that we have agreed to-take your deposition on Thursday, May 15.
If you elect to attend the l
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DAKER & DoTTS Mrs. Peggy Duchorn Page 3 April 21, 1980 Sinkin deposition, we will go ahead and take it in San Antonio.
If not, we will take it in Bay City at a mutually convenient place, either your office or the conference room of some Bay City establishment to be arranged.
We will be back in touch with you well before the deposition to tic down the exact place so that all interested parties may be given notice.
We have also committed to you, pursuant to your request, that Mr. Tom B'iddle will not be present at your depo-sition.
Very sincerely yours, Finis E.
Cowan FEC: 63 cc:
Mr. Charles Bechhoefer, Chairman Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Dr. James C.
Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A.
Luebke 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 Mr. Richard W.
- Lowerre, Assistant Attorney General for the State of Texas Post Office Box 12548, Capitol Station Austin, Texas 78711 i
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I N BAKER & CoTT,5
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Mrs. Peggy Buchorn Page 4 April 21,'1980 cc:
Honorable Burt O'Connell r
County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 Atomic Safety and Licensing Board Panel U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Chase R.
Stephens 4
Docketing and Service Section Office of the Secretary of the i
Commission U.
S. Nuclear Regulatory Commission 4
Washington, D.C.
20555 Mr. Jack Newman Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, N.W.
Washington, D.
C.
20036 Mr. Lanny Sinkin, Co-coordinator Citizens Concerned About Nuclear Power, Inc.
116 Villita San Antonio, Texas 78205 Mr., Shawn Rogers Brown & Root 4100 Clinton Drive 7th Floor Houcton, Texas 77020 Mr.
L.
R.
Jacobi Houston Lighting & Power Company Energy Development Complex Room B-372 Houston, Texas 77002 f.
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