ML19347B383

Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl

Date released: 12/27/2019	Download: ML19347B383

Affidavit Re Impact of Plant on Waterfowl & Other Environ Effects.Line No Longer Extends Over Lake & Thus Does Not Need to Be Moved.Prof Qualifications Encl

ML19347B398
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/01/1980
From:	Schlicht F HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B398 (20)

Response in Opposition to D Marrick 800911 Motion for Summary Disposition of Marrick Contention 2(c).Motion Lacks Statement of Facts or Admissible Evidence & Exceeds Scope of Contention.Certificate of Svc Encl

ML19347B396
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/02/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19347B396 (14)

Affidavit Re Latching.In Order for Radioactive Emissions to Effect Electronics on Aircraft,Aircraft Would Have to Park at Site Boundary for Extended Period.Certificate of Svc Encl

ML19347B394
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/11/1980
From:	Sumpter J HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B394 (16)

Response in Opposition to Tx Pirg Motion for Summary Disposition of Tx Pirg Addl Contention 50 Re Latching. Applicant Matl Statement of Undisputed Facts Remains Unchanged

ML19347B393
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/02/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19347B393 (13)

Affidavit Re Economic Comparison Between Competing Generation Alternatives.Util Does Not Qualify for Any Exemptions to Fuel Use Act Which Would Allow Unlimited Use of Gas for Unlimited Time.W/Certificate of Svc

ML19347B392
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/30/1980
From:	Buy J HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B392 (10)

Affidavit Re Natural Gas Plant Alternative.Util Not Automatically Entitled to Fua Exemption Because No Nonattainment Areas Exist in Houston.No Environ Exemptions Available to Util

ML19347B390
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/29/1980
From:	Mcguire W HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B390 (5)

Response in Opposition to Tx Pirg 800912 Motion for Summary Disposition of Tx Pirg Addl Contention 8 Re Natural Gas Alternative.As Matter of Law,Util Cannot Construct New Gas Fired Plants

ML19347B389
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/02/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19347B389 (8)

Affidavit Re Sources of Groundwater for Facility.Lakes Conroe,Houston & Livingston Can Supply Surface Water to Meet City Demands Through Yr 2000.Curriculum Vitae,Excerpts of C Johnson & Saxion Depositions & Certificate of Svc Encl

ML19347B388
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/29/1980
From:	Vansickle D TURNER COLLIE & BRADEN, INC.
To:
References
Download: ML19347B388 (44)

Affidavit Re Site Evaluation.Util Analysis Looks Only to Cost,Not to Benefit.Curriculum Vitae Encl

ML19347B387
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/30/1980
From:	Hussey J DAMES & MOORE
To:
References
Download: ML19347B387 (12)

Affidavit Re Allens Creek Vs South Tx Project Sites.Cost Comparison Tabulation Encl

ML19347B386
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/30/1980
From:	Mccuistion R HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B386 (12)

Response in Opposition to Tx Pirg Motion for Summary Disposition of Tx Pirg Contention 1 Re Site Comparison. Failure to Demonstrate Significance of Farmland pre-emption Is Fatal Defect.List of Remaining Issues in Dispute Encl

ML19347B385
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/02/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19347B385 (18)

Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl

ML19347B382
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/02/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19347B382 (13)