ML19343B205

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Requests Rewording of Applicant & NRC Joint Response to ASLB 801121 Order Re Intervenor Failure to Identify Expert Witnesses.Applicant Has Deposed Many Identified Witnesses
ML19343B205
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 12/08/1980
From: Hinderstein C
AFFILIATION NOT ASSIGNED
To: Wolfe S
Atomic Safety and Licensing Board Panel
References
NUDOCS 8012150199
Download: ML19343B205 (2)


Text

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RELATED COnnF.SPONDENCE Carro Hinderstein 609 Fannin, Suite 521 53 C

Houston, Texas 77002 e

4 C:.Q December 8, 1980 D

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%7 Sheldon J. Wolfe, Esq., Chairman Atomic Safety and Licensing Board Panel E,

U. S. Nuclear Regulatory Commission

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Washington, D. C.

20555

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3 Re: Docket No. 50-466 In the Matter of Houston Lighting

& Power Co. - Allens Creek Joint Response of Applicant and 7

NRC Staff to ASLB Order of November 21, 1980 (Received December 4, 1980)l-i

Dear Mr. Wolfe:

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In reference to the above Joint Response, I take exception to the second paragraph, page 2, which states in part "... since l

intervenors have not identified any expert witnesses to date, they have been allocated only one day to present direct testimony on each group of contentions."

I, and other Intervenors, have identified expert witnesses, and the Applicant has deposed many of them.

Some of these experts have been identified for well cver a ye-.

Irresponsible wording on the part of the Applicant and NRC St.aff such as this, is not condusive to a responsible l

hearing.

I request that this wording be amended to reflect the truth.

Sincerely,

' Original Signed By Carte Hinderstein Carro Hinderstein ec:

See attached list.

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Sheldon J. Wolfe December 8, 1980 Page 2 cc:

J. Gregory Copeland Baker & Botts Attorneys at Law One Shell Plaza Houston, Texas 77002 Dr. E. Leonard Cheatum Route 3, Box 350A Watkinsville, Georgia 30677 Mr. Gustave A. Linenberger Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555

. Chase R. Stephens t

Docketing and Service Section Office of the Secretary of the Commission Washington, D. C.

20555 Susan Plettman David Preister Texas Attorney General's Office P.O. Box 12548, Capitol Station Austin, Texas 78711 Richard Black l

Staff Counsel U. S. Nuclear Regulatory Commission l

Washington, D. C.

20555

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