ML19347F466

Response Opposing Doherty 810423 Motion to Reopen Record on Need for Power Contention.Aslb Should Issue Order That Motion Is Moot & Direct Applicant to Update Testimony on Need for Power Testimony Later.Certificate of Svc Encl

ML19347F466
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	05/08/1981
From:	Copeland J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8105190341
Download: ML19347F466 (4)

Text

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5/8/81 9

c w ena UNITED STATES OF AMERICA O N ,

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NUCLEAR REGULATORY COMMISSION -

11 4 t"' 121981 >

'BEFORE THE ATOMIC SAFETY AND LICENSING BOAR P

\y r g e s ser.

' /

In the Matter of S 4

g N HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466l g (Allens Creek Nuclear Generating S  :-i

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Station, Unit 1) S ff; APPLICANT'S RESPONSE TO DOHERTY v I' ~-

MOTION TO REOPEN THE R'ECORD ON NEED 0 FOR POWER ISSUES V/,

DnD .

Un  ?

' ' art w On April 23, 1981, Mr. Doherty filed a motion i

l reopen the record on the need for power contention in light of Applicant's announced plans to stretch out the construc-tion of all of its new power plants in order to ease the financial burden of constructing those plants. Mr. Doherty's l

motion is moot. On March 27, 1981, Applicant's attorney, l

Mr. Newman, wrote a letter to the Board advising them as to the stretched out construction schedule and further advised the Board that Applicant will update its need for power testimony. In se doing, Applicant will necessarily have to l address the proposed load management program referenced in Mr. Doherty's motion.

The only question remaining ir as to the timing of D3

%s further testimony. Since the changes in the construction program were brought about by financial considerations, Ap-plicant believes that it would be best to address both the 8185190341

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financial qualifications contention and the updated need for power information at the same time. The financial qualifications contention has been scheduled toward the and of the hearings so that the Board would have the most recent information available to it at the time it hears testimony on that contention. That same consideratica would

( indicate that it is appropriate to defer updating the record l on need for power so that the Board will also have the most I

current information available to it on demand and capacity projections at the time it hears testimony on finsacisl qualifications.

For the foregoing reasons, the Applicant suggests' that the Board issue an order denying Mr Doherty's motion as moot and directing that Applicant update its need for power testimony at the time it presents its testimony on financial qualifications.

l Respectfully submitted, OF COUNSEL:

I N ,,_

BAKER & BOTTS J ~Grego eland 3000 One Shell Plaza 00 One 1 Plaza Houston, Texas 77002 ouston, T as 77002 LOWENSTEIN, NEWMAN, REIS Jack R. Newman

& AXELRAD Robert H. Culp 1025 Connecticut Ave., N.W. David B. Raskin Washington, D. C. 20036 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY

u'P1/ m om.w $

mas

!p MAY 121981

• I UNITED STATES OF AMERICA %g NUCLEAR REGULATORY COMMISSION a sw. Y BEFORE THE ATOMIC SAFETY AND LICENSING BOA c, '

In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing __. _ __

Applicant's Response to Doherty Motion to Reopen the Re-cord on Need for Power Issues in the above-captioned pro-ceeding were served on the following by deposit in the -

United States mail, postage prepaid, or by hand-delivery this 8th day of May, 1981. -

Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 -

U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 Mr. Gustave A. Linenberger Atomic Safety and Licensing

. Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Mr. Chase R. Stephens Atomic Safety and Licensing Docketing and Service Section Appeal Board Office of the Secretary U.S. Nuclear Regulatory of the Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S. Nuclear Regulatory P. O. Box 12548, Capitol Station Commission Austin, Tcxas 78711 Washington, D. C. 20555

Bryan L. Baker Brenda McCorkle ,

1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan Bishop W. Matthew Perrenod 11418 Oak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A. Doggett Wayne E. Rentfro P. O. Box 592 P. O. Box 1335 Rosenberg, Texas 77471 Rosenberg, Texas 77471 John F. Doherty William Schuessler 4327 Alconbury 5810 Darnell Houston, Texas 77021 Houston, Texas 77074 Carro Hinderstein James M. Scott 609 Fannin, Suite 521 13935 Ivy Mount Houston, Texas 77002 Sugar Land, Texas 77478 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401

. Grego C land -

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