ML19339C309

Responds to Intervenor 801030 Request for Documents.Util Correspondence W/Nrc Re Const Deficiencies Available in Lpdr in San Antonio,Tx.Certificate of Svc Encl

ML19339C309
Person / Time
Site:	South Texas
Issue date:	11/06/1980
From:	Hudson T BAKER & BOTTS
To:	Eastman K Citizens Concerned About Nuclear Power, INC.
References
H-2480-760, ISSUANCES-OL, NUDOCS 8011180108
Download: ML19339C309 (4)

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H-2480-760 November 6, 1980 (STP/AOL) Z

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2 Ms. Kim Eastman ~

Citizens Concerned About Nuclear Power ',,' [1 5106 Casa Oro 5 ., . _ .

San Antonio, Texas 78233 3 .' ll Cf -:

RE: CCANP's Request for Documents dated October 30, 1980 ans' addressed to Mr. Oprea

Dear Ms. Eastman:

This letter is in response to captioned request which sought a large number of letters sent to the Nuclear Regulatory Commission (NRC) by Houston Lighting & Power Company (HL&P). As a preliminary matter, I would appreciate CCANP directing all future correspondence in this proceeding to HL&P's named representatives and not to HL&P in general or to specific HL&P employees. This procedure will facili-tate a timely response to the requests. We, in turn, will communicate only with CCANP's named representatives. As a practical matter, all discovery related correspondence should be sent to me.

The above captioned request sought all correspon-dence from HL&P to the NRC bearing numbers ST-HL-AE-363 through ST-HL-AE-565, except for the approximately 70 odd letters which were listed in the attachment. A' though CCANP's request described this correspondence as reports concerning "construc-tion deficiencies", the letters in question are believed to include a '.arge number of other matters. HL&P corresponds with the ' RC with respect to a lot of matters other than alleged ccastruction deficiencies. In addition, not all correspondence related to " construction deficiencies" is related to any contention pending in this proceedi.ng. Since HL&P has attempted to serve on CCANP all correspondance relat-ing to the accepted contentions, HL&P believes the requested documents are not relevant to this proceeding and, therefore, declines to produce them.

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CAKER & BoTTs Ms. Kim Eastman November 6, 1980 Page 2 Moreover, most, if not all, HL&P correspondence to the NRC regarding " construction deficiencies" should be on file in the NRC public document room in San Antonio, which is located in the main library at the corner of St. Mary and Market. Mr. Lanny Sinkin, appearing as a representative of CCANP, testified on deposition that thic document reposi-tory was created at the specific request of CCANP and was used by Mr. Sinkin in researching documents related to the contentions. HL&P suggests that CCANP obtain the requested documents from this public document room.

If you should have any further qvastions regarding this matter, please feel free to call on the undersigned.

Very truly yours, m

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Thomas B. Hudson, Jr.

TBH:44 cc: S?rvice List Attached

e CERTIFICATE OF SERVICE I hereby certify that the foregoing document has been served on the following indiciduais and entities by deposit,i,n the U.S. mail, first class, postage prepaid on this ")n _ day of November, 1980.

Thomas B.

ra h/Hudson, Jfr.

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cc: Charles Bechoefer, Esquire Docketing and Service Section Chairman Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James C. Lamb 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 Bernard M. Bordenick, Esquire Hearing Attorney Office of the Executive Legal Jirector U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard W. Lowerre, Esquire Assistant Attorney General for the State of Texas P. O. Box 12548 Austin, Texas 78711 Peggy Buchorn Executive Director Citizens for Equitable Utilities, Inc.

Route 1, Box 432 Brazoria, Texas 77422 Mr. Jack Newman Lowenstein, Newman, Reis Axelrad & Toll 1025 Connecticut Avenue, NW Washington, D.C. 20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel (5)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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