ML19341A874

Second Set of Interrogatories & Request to Produce Documents Directed to Citizens for Equitable Utils.Concerns STP Const Records.Certificate of Svc Encl

ML19341A874
Person / Time
Site:	South Texas
Issue date:	12/05/1980
From:	Hudson T BAKER & BOTTS, HOUSTON LIGHTING & POWER CO.
To:	CITIZENS FOR EQUITABLE UTILITIES
Shared Package
ML19341A873	List: ML19341A872 ML19341A874
References
ISSUANCES-OL, NUDOCS 8101280585
Download: ML19341A874 (3)

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, . ca UNITED STATES OF AMERICA BEFORE THE~ ATOMIC SAFETY AND LICENSING BOARD

'IN THE MATTER OF S '

HOUSTON LIGHTING & POWER S COMPANY, ET AL.

~ 5 Docket Nos. STN-498 OL (SOUTH TEXATPROJECT S STN-499 OL Units 1 & 2) S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING & POWER COMPANY, ET AL., TO CITIZENS FOR EQUITABLE UTILYTIIT, INC.

Preface Pursuant to Sections 2.740b and 2.741 of the Commission's Rules of Practice,. Houston Lighting & Power Company, Project Manager of the South Texas Project, acting on behalf of itself and the other applicants, the City of San Antonio, Texas, acting by and through the City Public Service Board of the City of San Antonio, Central Power and Light Company and the City of Austin, Texas (hereinafter

" Applicants") , propounds the following Interrogatories and requests for Production of Documents to Citizens for Equitable Utilities, Inc. (hereinafter "CEU"). Applicants incorporate herewith the instructions and definitions set forth in the First Set of Interrogatories and Requests for Production of Documents to CEU.

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- * ,Q Interrogatories & Requests for Production

1. Identify any individual or entity which CEU has reason to believe may possess STP construction records or documents, either originals or copies, other than the parties in this proceeding and their representatives.

Please include, but do not limit the answer to, the individual or entity in New York which Mrs. Buchorn has stated may possess such records.

2. Identify and produce any STP construction record.s or documents, either originals or copies, in CEU's possession other than. (i) those identified in response to previous inter-rogatories and (ii) those obtained from the Applicant or the NRC Staff in this proceeding.

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CERTIFICATE OF SERVICE I hereby certify that the foregoing document has been cerved on the following individuals and entities by deposit in the U.S. Mail, first class, postage prepaid on this #+L day of b w 6<. , 1980.

& __ =kY Thomas B. Hudson, Jr.

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Charles Bechoefer, Esquire Docketing and Service Section Chairman Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Pat Coy Dr. James C. Lamb Citizens Concerned About Nuclear 313 Woodhaven Road Power i

Chapel Hill, North Carolina- 27514 5106 Cass Oro San Antonio, Texas 78233 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

Bernard M. Borden.ick, Esq.

Office of the Executive Atomic Safety and Licensing Legal Director Board Panel (5)

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Brian E. Berwick Betty Wheeler, Esquire Assistant Attorney General Hoffman, Steeg & Wheeler for the State of Texas 1008 S. Madison P. O. Box 12548 Amarillo, Texas 79101 Austin, Texas 78711 Mr. Jack Newman Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, NW Washington, D.C. 20036 TH:4:H I

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