ML19350C638
| ML19350C638 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/16/1981 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC., CITIZENS FOR EQUITABLE UTILITIES |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8104060506 | |
| Download: ML19350C638 (3) | |
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NUCLEAR' REGULATORY COTiISSION A
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M sY5 JFORE-THE ATOMIC SAFETY AND LICENSING EOARD h
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5 Docket Nos. STN 50-498 OL HOUSTON LIGHTING AND 5
STN 50-409 OL POWER COMPANY, ET AL.
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(South Texas Project, 5
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Units 1 and 2) 4 ANSWERS OF MR. LANNY SINKIN TO QUESTIONS FROM APPLICANTS a
On December 4, 1980 by letter from Mr. Thomas B.
Hudson, Jr., Applicants requested answers to specific items On carried over from the deposition of Mr. Lanny Sinkin.
January 16, 1981, Applicants filed a Motion for Extension Said Of Time in Thich to Compel Answers to Interrogatories.
Motion is utill pending with the Atomic Safety and Licensing to the Board.Below are the answers from Mr. Lanny Sinkin questions identified in the December 4, 1980 letter.
l (The names of those members of CCANP who Item No. 2_
assisted Mr. Lanny Sinkin in answering Applicant Interroga-l I was assisted by tories)"In answering the interrogatories, Steven Sinkin and perhaps by William C. McGlothlin, Jr.
Both of these attorneys offered occasional legal assistance l
Kim Eastman and to me in my work as CCANP representative. assisted me in organizing.
Sandra Nobile, members of CCANP, material for. answering the second Applicant Interrogatories.
Essentially, I am solely responsible for the interrogatory answers.
Item No. 4 (Availability of a box of. documents and records on the subject of nuclear power accumulated by Mr. Sinkin over the past eight years)
"I have no intention of appearing,as an expert witness on the topic of nuclear power and, therefore, consider theIn answer to the' request irrelevant to these proceedings.
d question, however, prior to entering law school, I turne b all of my material relevant to nuclear power over to Pat pSas j 8'1f0406 Ost*
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Coy for CCANP filing.
The caterial is probably dispersed in those files."
Ite= No. 5 (Copies of various position papers prepared by Mr. Sinkin on the topic of nuclear power or the South Texas Nuclear Project)
"The answer to ite= no. 4 applies to this ite= also."
Ite= No. 6 (Atte=pting to obtain the consent of Mr. Swayze and.everyone involved in interviewing Mr. Swayze for the release of the taped conversation with Mr. Swayze)
"The tape in question was prepared under my direction as part of my activities as pro se attorney and is considered part of the work product of my wEFk in that capacity.
Nevertheless, through previous counsel Ms. Wheeler and through my own efforts, I have atte= ped to gain the necessary permissions without success."
Ite= No. 9 (Notes on conversations with Mr. Swayze)
"Any conversations I had with Mr. Swayze were conducted in my capacity as pro se attorney and are, therefore, considered privileged.
Nevertheless, I have sought to
. locate such notes but have not located any to date."
Ite= No. 10 (Identification of docu=ents used in answering interrogatories or exa=ined in connection with the intervention, other th== Brown and Root docu=ents, ELF.:P documents, and the Dece=ber 16, 1979 " bundle of docu=ents")
"The question is considered unduly burdensc=e and vague but I will endeavor to answer it.
I have exa=ined hundreds of-pages of NRC documents in the public docu=ent roc =.
It would require many hours of labor to specify which ones.
I have also read technical papers, books, pa=phlets, and other educational caterial.
I do not, however, intend to be an expert witness in these proceedings."
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i Lanty Sinkin State of Texas 5 County of Travis!
BEFORE_ME, the undersi,, ed authority, on this day
_ personally appeared Lanny Alan Sinkin, who on his oath states that he has read the foregoing ANSTERS Oy MR. LANNY SINKIN TO. QUESTIONS FROM APPLICANT and knows the sa=e to be M.=:f true and correct.
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4-3 Lanny #inkin SUBSCRIBED AND SWORN-to before =e by LANNY SIiEIN on this ' /4 /4 day of. March, 1981.
wi s a d w ( c f n,,i r $ 4
' Notary Public fn and
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My Commission expires: //-2/-f#
for Travis County, Texas
!l Certificat; of Service I'hereby certify that the foregoing document has been served on the following individuals and entities by hand (*) or by deposit in the U.S. Mail,.first class, postage prepaid on this /41 day of March, 1981.
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Mr. Jack Newman Charles Bechhoefer,' Esquire
- Lowenstein, Newman, Reis, Axeirad, & Toll Chairman Atomic Safety and Licensing Board 1025 Connecticut Avenue, NW U.S. Nuclear Regulatory Commission Washington, D.C. 20036-Washi7gton, D.C. 20555 Docketing and Service Section (7)
Dr. James C. Lamb
- Office of the Secretary 313 Woodhaven Road U.S. Nuclear Regulatory Comiission Chapel Hill, North Carolina 27514 Washington, D.C. 20555 Mr. Ernest E. Hill Atomic Safety and Licensing Lawrence Livermore Laboratory Board Panel
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University of California U.S. Nuclear Regulatory Commission P.O. Box 809, L-123 Washington, D.C. 20555 Liver = ore, Ca.
94550 Atomic Safety and Licensing Edwin J. Reis
- Appeal Panel (5)
Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Brian E. Berwick Assistant Attorney General for the State of Texas
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Peggy Buchorn Route 1, Box 1684 Brazoria, Texas 77422 l
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