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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence ML20010G0731981-08-24024 August 1981 First Set of Interrogatories Directed to NRC Re Contention 21.Certificate of Svc Encl.Related Correspondence ML19343B7071980-12-0505 December 1980 Response to First Set of Interrogatories & Request for Production of Documents from Util on Health Effects of Low Level Radiation.Certificate of Svc Encl.Related Correspondence ML19340C3141980-11-10010 November 1980 Response to W Schuessler Request for Addl Answers to First Set of Interrogatories.Applicant Is Not in Possession of Data Analyzing Hypothetical Significant Offsite Radiological Releases.Certificate of Svc Encl ML19339C0471980-11-0606 November 1980 Response to W Schuessler Second Set of Interrogatories & Requests for Production of Documents.Describes Discussions W/Austin County,Tx Sheriff Dept Re Evacuation Analysis. W/Affidavit,Prof Qualifications & Certificate of Svc ML20008E3971980-10-22022 October 1980 First Set of Interrogatories & Requests for Production of Documents Directed to E Cumings,R Griffith,L Johnston & R Lemmer Re Consolidated Contention on Effects of low-level Radiation.W/Certificate of Svc.Related Correspondence ML20062J4311980-10-20020 October 1980 Informal Request for Addl Responses to First Set of Interrogatories & Requests for Production of Documents,In Lieu of Motion to Compel.Includes Second Set of Interrogatories Directed to Util.Related Correspondence ML19347C1851980-10-14014 October 1980 Amended Response to First Set of Interrogatories.Info Includes Identity of Individuals Directing Site Selection. Certificate of Svc Encl.Related Correspondence ML19332B1801980-09-24024 September 1980 Response to Intervenor Schuessler First Set of Interrogatories & Requests for Production of Documents. Requested Documents & Certificate of Svc Encl ML19347A6951980-09-22022 September 1980 Response to Fh Potthoff Third Set of Interrogatories.Objects to All Questions Due to Irrelevancy.Affidavits & Certificate of Svc Encl.Related Correspondence ML19332A8501980-09-0909 September 1980 Further Response to Tx Pirg 16th Interrogatories.Discusses Future Prices of Gas,Nuclear & Coal Energy,Personnel Qualifications,Control Room Design,Safety Relief Valve Setpoints & Hydrogen Explosion.Certificate of Svc Encl ML19351D1451980-09-0505 September 1980 First Set of Interrogatories & Request for Production of Documents Soliciting Info Re Results of Accident at Site, Emergency Plan & Demographics.Certificate of Svc Encl. Related Correspondence ML19344D8731980-08-18018 August 1980 Response to Potthoff Second Set of Interrogatories. Percentage of Electric Generation by Natural Gas Will Be 68% & 21% by 1985 & 1990,respectively.Objects to Remaining Interrogatories.Certificate of Svc Encl ML19327A5091980-08-0101 August 1980 Second Set of Interrogatories Directed to Applicant. Questions Feasibility of Marine Biomass Farm as Alternative to Facility.Certificate of Svc Encl ML19327A5021980-08-0101 August 1980 Response to Applicant First Set of Interrogatories. Intervenor Has No Intention to Call Expert Witnesses at Present Time ML19327A2261980-07-28028 July 1980 Response to Financial Qualifications Intervenors Fourth Set of Interrogatories.Discusses Program Improvements Made as Result of South Tx Project Incidents,Prefiling Package & H Dean Testimony.Affidavit & Certificate of Svc Encl ML19330B2061980-07-25025 July 1980 Response to Jm & M Bishop 800705 Interrogatories & Requests for Production of Documents.Identifies Witnesses & Summarizes Substance of Testimony.Certificate of Svc & Prof Qualifications Encl.Related Correspondence ML19321B2591980-07-25025 July 1980 Response to 800709 Interrogatories & Request for Production of Documents.Includes Info Re Natural Gas Alternative, Conservation & Interconnect,Error in Computer Program & Technical Qualifications.Certificate of Svc Encl ML19321B2641980-07-25025 July 1980 Response to 800706 Interrogatories & Requests for Production of Documents.Includes Info Re Movement of Brazos River Toward Proposed Pipeline Route & Max Peak Overpressure for Each Critical Structure.Certificate of Svc Encl ML19330A7151980-07-23023 July 1980 Response to Potthoff First Set of Interrogatories.Objects to Majority of Interrogatories on Basis of Irrelevancy. Applicant Has Not Commissioned Study on Marine Bio Farm Feasibility to Provide Synthetic Gas.W/Certificate of Svc ML19330C5521980-07-0909 July 1980 Response to First Set of Interrogatories.Lists Documents Relied Upon in Study of Effect of Power Transmission Lines on Migratory Waterfowl & Identifies Experts.Affidavit, Resume & Certificate of Svc Encl.Related Correspondence ML19320C3151980-07-0909 July 1980 Response to Intervenor D Marrack 800508 Interrogatories. Identifies Expert Witnesses Expected to Be Called in Support of Consolidated Rentfro Contention 2.Affidavit & Certificate of Svc Encl ML19320C5611980-07-0909 July 1980 Interrogatories & Request for Production of Documents Directed to Nrc.Requests Factual Basis of Anticipated Testimony Re Natural Gas Use as Fuel & Subsequent Costs of Electricity.W/Certification of Svc.Related Correspondence ML19320C9271980-07-0909 July 1980 First Set of Interrogatories Directed to Houston Lighting & Power.Requests Factual Info Re U Fuel Sources,Costs,Method of Mining & Stripping,Site & Extent of Mining & Feasibility of Marine Biofarm for Synthetic Natural Gas Supply ML19320C2691980-07-0808 July 1980 Response to Applicant Second Set of Interrogatories & Request for Production of Documents Re Intervenor Pleadings Before ASLB & Aslab.Certificate of Svc Encl ML19330A3501980-07-0808 July 1980 First Set of Interrogatories Directed to NRC Re Financial Qualifications,Hearing Expectation & Witnesses Intended to Be Called ML19330A3421980-07-0808 July 1980 Fourth Set of Interrogatories Directed to Util Re Financial Qualifications.Includes Questions on Disciplinary Actions & Role of Houston Industries.Related Correspondence ML19320C2651980-07-0808 July 1980 Response to Applicant First Set of Interrogatories & Request for Production of Documents Re Impact of Transmission Lines & Fes ML19320C2701980-07-0808 July 1980 Response to D Marrack First Set of Interrogatories.Includes Statements Re Transmission Lines & Alternative Transmission Sites & Routes.Prospective Witness Fj Schlight Prof Qualifications,Affidavit & Certificate of Svc Encl ML19330B2091980-07-0606 July 1980 Interrogatories & Request for Documents Directed to Util. Requests Most Recent Population Projection Data & Methodology Used for Updating Projection.Related Correspondence 1982-06-15
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
[Table view] |
Text
_ _ _ - _ _ _ _ _ _
_BE.AIED. CORRESPONDENS September 22, 1980 UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION 9
BEFORE THE ATOMIC SAFETY AND LICENSING BO D0 %
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In the Matter of 5 SEP 2 5 % > -
HOUSTON LIGHTING & POWER "
COMPANY Docket No. 50-466 C) I'd 5 p (Allens Creek Nuclear I*
Generating Station, Unit 5 No. 1) 5 APPLICANT'S RESPONSE TO POTTHOFF'S THIRD SET OF INTERROGATORIES TO HOUSTON LIGHTING &
POWER COMPANY In response to the interrogatories propounded by Intervenor F. H. Potthoff, III, Houston Lighting & Power (Applicant) answers as follows:
INTERROGATORY NO. 1:
In theg FES, S.10.4.1.q [ sic], it states ACNGS will produce 7.9 x 10 kwh/ year (at 80% average capacity). Does Applicant contest this figure? If so, why?
ANSWER:
The cited figures from the FES are consistent with figures reported in the ER Supplement at S11.1.1.
INTERROGATORY NO. 2:
In Applicant's Motion for Summary Disposition on my Contention 6, Dr. Buck of the Appeals Board is quoted as saying ACNGS is designed to produce 107 x 10" BTUs/ year.
Does Applicant know how Dr. Buck arrived at this figure? If so, please give a full explanation. If Applicant does not know, how does it know this figure is correct?
p$ b 80093000N $0I
ANSWER:
Applicant objects to this question. Dr. Buck is an officer of the Atomic Safety and Licensing Appeal Board of the Nuclear Regulatory Commission. Applicant has no legal obligation to explain or defend his factual analysis or to do independent analyses to satisfy itself of the accuracy of his work.
INTERROGATORY No. 3:
In the Motion for Summary Disposition on my Contention 6, Dr. Herbert Woodson says on page 4 of his affadavit [ sic]
that ACNGS will have a heat rate of "10,000 STU/KWH." [a]
Does Dr. Woodson understand this is due to the fact nuclear fission generates higher temperatures than burning coal or natural gas? [b] Does Applicant understand this?
ANSWER:
[a] Applicant objects to this question. It is not proper to inquire about the opinions of experts through interrogatories to Applicant. If Intervenor had wished to explore Dr. Woodson's reasoning, he should have deposed i Dr. Woodson.
[b] The controllirig factors for cycleThe efficiency temperature are the temperature and pressure of the steam.
and pressure of steam in coal or natural gas-fired boilers are typically higher than in nuclear steam generators.
INTERROGATORY NO. 4:
[a] Because of the above, does Dr. Woodson under-stand that his statement on page 4 of his affadavit [ sic]
that ACNGS musy be replaced by a " yearly thermal input of about 70 x 10' BTU" isn't necessarily true? [b] Does Applicant understand this?
ANSWER:
[a] See answer 3 [a] above.
[b] Applicant has no disagreement with Dr. Woodson's conclusion.
I l
1
INTERROGATORY NO. 5:
In his affadavit [ sic], Dr. Woodson states that there is no evidence that a " biomass farm would be environ-mentally preferable to a nuclear power plant." Did Dr. Woodson consider :the environmental effects of stripmining for uranium when comparing a biomass farm to ACNGS?
ANSWER:
See answer 3(a] above.
INTERROGATORY NO. 6:
In answer to my first set of interrogatories, Applicant states that it has contracted for uranium with What is their mailing address?
Atlas Minerals Corporation.
ANSWER:
Applicant objects to this question. It is not relevant to Potthoff Contention 6. Nevertheless, Applicant answers that the mailing address of Atlas Minerals Corporation is 353 Nassau Street, Princeton, New Jersey 08540.
INTERROGATORY NO. 7:
In an answer to my first set of interrogatories, Applicant states that the uranium from Atlas Minerals has already been mined. [a] Does this mean Atlas Minerals only deals in mined uranium? [b] Can Applicant find out where Atlas Minerals gets its uranium? [c] If so, please tell me.
ANSWER:
I Applicant objects to this question. It is not relevant to Potthoff Contention 6. Nevertheless, Applicant i answers as follows:
[a] Applicant reported previously that "the Atlas Minerals Corporation's uranium has already been mined."
This statement means exactly what it says and nothing more.
[b] No.
[c] Not applicable.
I
8: d all PrERROGATORY NO.
[a] Does Applicant [b]intend DonstoApplicant buy any plan an to[c] Does uranium it can to fuel ACNGS?
buy uranium that was strip-mined?g to buy ur ANSWER: i It is not Applicant objects to this quest on.Nevertheless, Applican fuel relevant to Potthoff Contention 6.
Applicant intends to obtain all theits normal oper answers as follows:
[a]
necessary to operate ACNGS for i this
[b] - [c] Applicant intends to obta n ,
nuclear fuel on the open market. I INTERROGATORY NO. 9: i of the table /
Does Applicant contest the find ngs .
on p. S.5-33, FES?
ANSWER: i It is not Applicant objects to this quest on.Furthermore, the FE licant is not required toNevertheless, relevant a product ofto thePotthoff Staff, and Contention App disagree 6. it.
with ent disagreement with j
I explain, defend, agree with, orApplicant answers '
the cited table. Respectfully submitted, d( Gil ^
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J. Gregory Copeland C. Thomas Biddle, Jr.
OF COUNSEL: Darrell Hancock 3000 One Shell Plaza 77002 BAKER & BOTTS Houston, Texas 3000 One Shell Plaza 77002 Houston, Texas Jack R. Newman Robert H. Culp LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL David B. Raskin 1025 20036 Connec 1025 Connecticut Avenue, 20036 N.W. Washington, D.C.
Washington, D.C.
ATTORNEYS FOR APPLICANT HOUSTCN LIGHTING & FOW COMPANY DH:4:F l l
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i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S
HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 S
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- Generating Station, S Unit No. 1) S i
AFFIDAVIT l THE STATE OF TEXAS S S
COUNTY OF HARRIS S
- I, PAUL A. HORN, first being sworn, depose and l state that I have answered Interrogatories 6, 7 and 8 of the foregoing Applicant's Response to Potthoff's Third Set of Interrogatories to Houston Lighting & Power Company in my capacity as Project Manager for Houston Lighting &
l Power Company, and that all ste.tements contained therein l are true and correct to the best of my knowledge and belief.
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Paul A. Horn SUBSCRIBED AND SWORN TO before me on this the C2_. day of 22 %2'uo, 1980. .
- 001lvttL 0 W/ Lek!veav Notary Public in and fo Harris County, Texas l My Commission Expires l
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< '< / , ,.;. 3 g ' - l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l S \
In the Matter of S J S l HOUSTON LIGHTING & POWER S Docket No. 50-466 i COMPANY 5 l S /
(Allens Creek Nuclear S i Generating Station, S i Unit No. 1)
AFFIDAVIT _ l j
S THE STATE OF TEXAS S
COUNTY OF HARRIS S l
first being sworn, depose and '
I, W. F. McGUIRE, 1, 4(b}
state that I have answered Interrogatories No.and 9 of Third Set of Interrogatories to Houston Lighting & Power Company in my capacity as Manager of the Environmental Protection Decartment of Houston Lighting & Power Company, and that a' 'tew-"ts
. contained therein are true and
.r my knowledge and belief.
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I ,Y [_P W. F. McGuire SUBS,CRIBED and SWORN TO before me on this the 1980
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dNotary A >APublic
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S
HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 (Allens Creek Nuclear s NI t ' S> /
Generating Station, S A'\ O Unit No. 1) S 8 ' . ,.
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I, LYNN J. KLEMENT, first being sworn, depose and state that I have answered Interrogatory No. 3[b] of the foregoing Applicant's Response to Potthoff's Third Set of Interrogatories to Houston Lighting & Power Company in my capacity as Assistant Reactor Engineer for Houston Lighting & Power Company, and that all statements contained therein are true and correct to the best of my knowledge and belief.
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brKn J. ent SUBSCRIBED ND SWORN TO before me on this the c2 day of @ . , 1980.
V Not&ry Puclic fn and for Harris County, Texas {
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UNITED STATES OF AMERICA ",' -
NUCLEAR REGULATORY COMMISSION M' $ . ',/
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5 i
HOUSTON LIGHTING & POWER S COMPANY $ Docket No. 50-466 5
(Allens Creek Nuclear 5 Generating Station, Unit 5 No. 1) 5 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Response to Potthoff's Third Set of Interrogatories to Houston Lighting & Power Company in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 22nd day of September, 1980.
Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatufo Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission Cornty Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Mr. Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555
Mr. William Schuessler Atomic Safety and Licensing 5810 Darnell Board Panel Houston, Texas 77074 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Steve Sohinki, Esq.
Staff Counsel Ms. Carro Hinderstein U. S. Nuclear Rgulatory Commission 609 Fannin, Suite 521 Washington, D.C. 20555 Houston, Texas 77002 Dr. D. Marrack Mr. Bryan L. Baker 420 Mulberry Lane 1118 Montrose Bellaire, Texas 77401 Houston, Texas 77019 Ms. Brenda McCorkle Mr. J. Morgan Bishop 6140 Darnell 11418 Oak Spring Houston, Texas 77074 Houston, Texas 77043 Mr. W. Matthew Perrenod Stephen A. Doggett, Esq. 4070 Merrick P. O. Box 592 Houston, Texas 77025 Rosenberg, Texas 77471 Mr. Wayne E. Rentfro Mr. John F. Doherty P. O. Box 1335 4327 Alconbury Rosenberg, Texas 77471 Houston, Texas 77021 Mr. James M. Scott Mr. F. H. Potthoff 13935 Ivy Mount 7200 Shady Villa, No. 110 Sugarland, Texas 77478 Houston, Texas 77055 F
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