ML20003F789

Response in Opposition to Applicants' 810409 Motion Seeking Sanctions Against Citizens Concerned About Nuclear Power,Inc for Failure to Comply W/Aslb Order.Inspectors Were Listed in 810330 Protective Order.Certificate of Svc Encl

ML20003F789
Person / Time
Site:	South Texas
Issue date:	04/14/1981
From:	Coy P Citizens Concerned About Nuclear Power, INC.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8104230597
Download: ML20003F789 (2)

Text

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UNITED STATES OF AFERICA ,

• D NUCLEAR REGULATORY COEISSION i, 000 D es

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EEFORE THE ATOMIC SAFETY AND LICENSING BOARD , Pg 16 ;gg$ ,

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IN THE MATTER OF 4 kp HOUSTON LIGHTING AND POWER ) Alll&'

DOCKET NOS. 50-498 0 COMPANY H AL.

) 50-499 OL (SOUTH TEXAS PROJECT, APRIL 14, 1981 UNITS 1 & 2)

CITIZENS CONCERNED A30UT NUCLEAR POWER, INC. RESPONSE TO APPLICANTS' MOTION FOR SANCTIONS FOR FAILURE TO COMPLY WITH ORDER COMPrLT,TNG DISCOVERY On April 9,1981, Applicants filed a motion seeking sanctions against Citizens Concerned About Nuclear Power. Inc.

(CCANP) for allegedly failing to comply with an order (the Order) of the Atomic Safety and Licensing Board (ASLB). The Order

, in question stated - as Applicants quote in their motion:

CCANP is further directed to review the tape recording it received from Mr. Swayzc's attorneys and provide pursuant to the Protective Order the identities of the inspectors interviewed in such recording if they provided infomation relevant to Contentions 1 and 2 cr info mation likely to lead

.to infomation relevant to Contentions 1 and 2.

(emphasis added)

In fact the identities of the inspectors were included in.the list of names provided under the Protective Order on o3 March 30,1981. I Applicants have the same opportunity to discover relevant infomation from these persons as they //

have for all other persons named. Had the Applicants =erely inquired of CCANP regarding this matter, they could have saved the 3 card and CCANpWho,t7ouble of dealing with a frivolous motion.

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/ 'b Respectfully submitted, it KM, o.eS\#

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", ' p L-l Citizens Concerned About Nuclear Power, Inc.

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F CERTIFICATE OF SERVICE I hereby certify' that the foregoing document has been served on the following individuals and entities by deposit in the U.S. Mail, first class, postage prepaid on this 14th day of April, 1981.

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Pat Coy g)

Charles 3echhoefer, Esq. Docketing and Service Section (7)

Chair =an, Atcmic Safety and Office of the Secretary Licensing Board U.S. Nuclear Regulatory Commissic-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington , D.C. 20555 Atomic Safety and Licensing Dr. James C. Lamb Board Panel 313 Woodhaven Road U.S. Nuclear Regulatory Comm.

Chapel Hill, North Carolina 27514 Washington, DC 20555 Mr. Ernest C. Hill Atomic Safety and Licensing Lawrence Livermore Laboratory Appeal Panel (5)

University of California U.S. Nuclear Regulatory Comm.

P.O. Box 809, L-123 Washington, D.C. 20555 Livermore, California 94550 Thomas 3. Hudson, Jr. Esq.

Edwin J. Reis Baker & Botts

, Office of the Executive 3000 One Shell Plaza Legal Director Housten, Tx. 77002 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

- \.-~. i 9 3rian E. 3erwick, Esq. /## /

Assistant Attorney General for [ D the State of Texas ce,743 5th floor, Reagan Eldg. f APg j0 ,

$2 Austin, Tx. 78711 y c, ---

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Mrs. Peggy Buchorn ;s'3 2&rf /

Executive Director, CEU 9 jf'?%p D #3 Route 1, Sox 1684 9 Brazoria, Tx. 77422 gg lu Mr. Jack Newman Lowenstein, New=an, Reis, & Axelrad 1025 Connecticut Ave. NW Washingten. D.C. 20036

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