ML19323G622

Interrogatories & Requests for Production of Documents Re Consolidated Contention 2 Concerning Effect of Transmission Lines on Human Health.Marrack 800502 Ltr to Util & Certificate of Svc Encl

ML19323G622
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	05/03/1980
From:	Marrack D, Renfro W AFFILIATION NOT ASSIGNED, MARRACK, D.
To:	HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8006060392
Download: ML19323G622 (6)

Text

,

• . _ .~ UNITED STATES OF AMERICA v -

NUCLEAR REGULATORY COMMISSION I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the'Maeter of S BEMED CORRESP0tGMCE 3

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

(Allens Creek Nuclear Generating S S tation, Unit 1) S INTERROGATORIES AND REQUESTS JOR PRODUCTION QE DOCUMENTS co 7

TO HOUSTON LIGHTING & POWER COMPANY poCgED j us**

b 3\gB0

• Pursuant to 10 CFR 52.740(b) and $2.741, Interveno sg

. David Marrack propounds the following Interrogatorie #Ng 4Y tv and Requests for Production of Documents to Houston Lightin to

& Power Company, hereinafter called " Applicant". 'Each inter- I rogatory should be answered separately and fully in writing under oath of affirmation by the person or persons making them no later than 14 days after service of these Inter-rogatories and Requests for Production, and each document requested should be produced no later than 30 days after service of these Interrogatories and Requests for Production.

within the limits of the City of Houston for inspection and copying.

Each question is instructed to be answered in 8 parts, except where inapplicable, as follows: ,

A. Provide the direct answer to the question.

B. Identify all documents and studies, and the particular parts thereof, relied upon by the Applicant, now I or in the past, which serve as the basis for'the answer. Provide copies of any such documents.

l C. Identify all documents and studies , and the particular parts thereof, examined bte n'ot relied upon by the ] *p \

Applicant, which pertain to the subject matter .

questioned. Provide a copy of each such d.ocument .

8 0 0 6.0 6 03 9;t 4 and study. -

I _ _ . _ _

N, .

D.

]

Id:ntify by name, title end effiliation each Applicant employee, consultant, 1 contractor or subcontractor ,

5 y that has the expert knowledge required to supp ort L the answer to the question.

k Identify by name, title and affiliation each person, as described  ;

above, who answers each question of these Interro -

gatories.

E.

Explain whether the Applicant is presently engaged or intends to engage in any further research or work which may affect the Applicant's answer.

Identify such research or work.

F.

Identify 'the witnesses, expert or non-expertif ,

l any, whom the Applicant intends to have testify on the subject matter questioned. '

i

~

State the quali-G.

fications of each such witness. -

Provide a summary of the testimony eachness wit in part F above is expected to offer and

, state'the' factual basis for each conclusion or opinio {

n each e

i such witness expects to present or.drnw in such E expert's testimony. -

H. 5 Identify all documents prepared by, for , or under  ;

the supervision of each such expert witn ess as - p g

i identified in par.t F above.

Include work papers, perliminary outlines and memoranda and communicatio ns between such expert and App;.icant .

that are relied 5.i:

upon by such expert in formulating the expert's E=4 opinions and conclusion. ((

Pr') vide copies of any e.::.

such documents. '

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. a ,. - -

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h 2 lhN Intervenor Interrogatories and request for copies of documents.

1./ The full text of the testimony of Gerald.e. Gears in the matter of consolidated Contention No.P. of Mr. Rentfro; See attatchment A Front sheet of G.E. Gears " Supplementary; Testimony" is requested.

2./ Clearly identify, including title, name of author (s), date and literature reference,all documents you are relying on in support of your position that the substance of consolidated contention No.2 of Rentfro is not true and correct.

3./ List by full title with date of release and date of filing with the EnvironmentalProtection Agency (.E.P. A. ) all documents consideredto constitute the full Environmental Impact Statement in this matter and specifically produce all documents, memos correspondence and related works.nofes or material.since the F.E.IS '

November 1974 4./ Provide the full names and addresses and CV's of all those on whose evidence you intend to rely in support of your claim that thqr l they are experts in the matter of the consolidated Eentfro . .

contention (2)two.

5./ state for persons named in 4./ above the particular qualificati?.nq .

which give them expertise in the area of the evidence from them on which you are relying.

I o zs - -c-aHJ cAk l90. ;L

y ,a

.i n SION urukt THE ATOMIC SAFETYAfin f

k ',

• I In the Matter of

'AND

( ,

' , CENSING BOARD HOUSTON LIGHTING R COMPANY

& POWE )

} '

. (Allens Unit 1) Creek Nuc' lear G )

enerating Station, )

) Docket No. 50-46

) .

1

)

NRC STAFF o SUPPLEMENTALF TESTIMONY O

\

In this proceeding ON CONTiNTION NO. 2- GERALD E W. E. Rentfro:

, the intervenors have' advanced th' .

on human health hasThe electrical e following impact of contentions:

the 345,000 not been adequately evalu volt t transmi ssion lines \

The Staff has a ed. i

\

humans in the Allens Crconsidered the ef .

i

" Final Envi of ronment'alections Statement (SeekentsHuclea a on this tastimony is to 5.3.4, 5.5.1 2on Final Supplem e and animals. supplement the above docu . , and 5.11.2).

as a member The Staff is working wit:h ment as The purpose ,

Effects of the Federal.Interagenc epa, DOE, FEA, and otherela s which is funding research y Advisory Committee r Federal agencies Based upon the review on all aspects on Electric Field of believe that changes in ththe latest find'ings of electric o field effects e applicant's proposed desin this oes not matter To authorize constructio n gn are warranted.

concerning acceptable s levelof Hpt's proposed c 345 kV fa il .

\

design or operating of exposure to ities, final decisions n co di various

- tions, may be made at th effects, and consequent e co e OL stage except in r)::

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MAY131980 ' E Office of the seastus pgketing & Senic' 1; v#

.._  % Br nth 7908150 3 9 8- g y * .

6 6 .

. 420 Mulberry IAnn Bellaire, Texas 77401 May 2, 1980 Darrell Hancock Attorney for Houston IA Ehting and Power c/o Baker and Botts

• Che shell Plaza Houston, Texas 77002 Wayne E. Rentfro P.O. Box 1335 Rosenberg, Texas 77471 Gentlemen:

In response to your letter of 18th April,1980 y understanding is as follows; A) he substance oI my contention (2b) is consolidated with Mr.Rentfro's l 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 limit for ' discovery' chat initiated upon the acceptance of my contention (2b) in the ' order 11 March,1980 is unaffected by this proposed censolidation of my contention (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 communications shall be sent to both Mr. Rentfro and myrelf at our respective addresses.

If this is not your understanding please advise Mr. Rentfro and gself within 7 days of receipt of this letter.

Yours respectfully,

/MV O Dk d Marrack f DOCKETED Intervenor /p USNRC 4

m/ms g f. FAY 131980 >- 2 CC Mr. Rentfro ( ,

Office of the Secretary

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Docketi."<E & Service ll B.*2*ch

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• • UNITED STATES OF AMERICA , .

NUCLEAR REGULATORY COMMISSION .u cs' O

'h.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD p'9- D%,q , .,

ust,p3 \;

a f- . . T In the Matter of 5 D g[$.[,j C D D HOUSTON LIGHTING ~& POWER 5

h ~: M 'UBEnn:n ./

q,% f'JC c COMPANY $ Docket No. 50-466 / yy

,Allens

( creek Nuclear 5 M 5 i

! Gener ting Station, Unit 5  !

! No .' ' .I ) g  !

t l .

CERTIFICATE OF SERVICE I. hereby certify that copies of the foregoing were served on the following by deposit in the United

} mail, postage, prepaid, or by hanc1-delivery.

Sheldon Y.'Wolfe, Esq.. Chairman Richard Lowerre, Esq. I Atomic Safety and Licensing Assistant Attorney General l Board Panel for the State of Texas i i

U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Dr. E. Leonard Cheatum Route 3, Box 350A Watkinsville, Georgia 30677 Stephen A. Doggett, Esq. I P. O. Box 592 l Mr. Gustave A. Linenberger Rosenberg, Texas 77471 l Atomic Safety and Licensing Board Panel Mr. John F. Doherty U.S. Nuclear Regulatory Commission 4327 Alconbury l

. Washington, D. C. 20555 Houston, Texas 77021 Mr. Chase R. Stephens Robert S. Framson Docketing and Service Section Madeline Bass Framson Office of the Secretary of the 4822 Wayncsboro Commission Houston, Texas 77035 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Carro Hinderstein R. Gordon Gooch, Esq. 8739 Link Terrace Baker & Botts Houston, Texas 77025 1701 Pennsylvania Avenue, N. W.

Washington, D. C. 20006 - Ms. Brenda McCorkle 6140 Darnell Houston, Texas 77074 Atomic Safety and Licensing Mr. W. Matthew Perrenod Board Panel 4070 Merrick U.S. Nuclear Regulatory Houston, Texas 77025 Commission Washington, D. C. 20555 Mr. Wayne E. Rentfro P. O. Box 1335  ;

Rosenberg, Texas 77471 l Steve Schinki, Esq.

Staff Counsel .

.Mr. James M. Scott U.S. Nuclear Regulatory Commission 13935 Ivy Mount Washington, D.;C.i.205f5 . .,- . .

Sugar Land, Texas 774,78 - -

- _ . . - .