ML20031F863

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Requests Paragraph 3 to ASLB 811008 Memorandum & Order Be Clarified as Listed.Certificate of Svc Encl.Related Correspondence
ML20031F863
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 10/14/1981
From: Newman J
AUSTIN, TX, CENTRAL POWER & LIGHT CO., HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, SAN ANTONIO, TX
To: Bechhoefer C, Bechoefer C, Eva Hill, John Lamb
Atomic Safety and Licensing Board Panel
References
NUDOCS 8110200492
Download: ML20031F863 (5)


Text

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October 14, 1981 J..

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i OCT.l 9 ;OOIA ;f Charles Bechhoefer, Esquire E s.,.

Chief Administrative Judge D

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Atomic Safety and Licensing Q

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Board Panel U.S. Nuclear Regulatory Commission s'

Washington, D. C.

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Dr. James C. Lamb, III Administrative Judge 313 Woodhaven Road Chapel Hill, North Carolina 27514 Ernest E.

Hill Administrative Judge Lawrence Livermore Laboratory Post Office Box 808, L-123 Livermore, California 94550 RE:

Houston Lighting & Power Co. et al.

South Texas Project, Units 1 & 2, Docket Nos. STN-50-498, STN-50-499 Gentlemen:

We have received a copy of the Board's Memorandum and Order (Concerning Changes in Schedule for Hearings) dated October 8, 1981, reflecting the results of the telephone conference call held on October 7, 1981.

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  • Low [w::Tzad, NSWEAN, Rzza & Axzt.cAn Charles Bechhoefer, Esquire Dr. James C. Lamb Ernest E.

Hill Page Two October 14, 1981 The Order appropriately documents (at pages 4-5) the actions taken by the Board as a result of the con-ference call.

In view of the number of subjects that were reported on by the parties during the conference call, however, the full paragraph on page 3 of the Order refers to several matters in a manner which we believe can usefully be clarified as follows:

(1)

The paragraph indicates that Applicants "will attempt to provide the parties with a status report on the project reorganization by November 3, 1981.

As discussed with the parties and the Board, that report will be limited to advising the parties whether Brown &

Root will continue to have a role in the Project and to describing the expected functional QA/QC responsibilitien of HL&P, Bechtel and Brown & Root.

(2)

The paragraph states that "between November 20 anu December 16 the intervenors would attempt to provide their reformulated position on various issues."

These specific dates pertain only to the period within which the intervenors will identify to the Board and the parties ary of their previously identified witnesses as to past events that they still plan to call.

(Those witnesses would tes-tify first at the resumed hearing session during the week of January 18, 1982, and would be followed by the NRC Staff witnesses.)

The views of the intervenors concern-ing issues to be heard and any need for discovery would be filed by November 23, either as part of a joint submit-tal of all of the parties or as separate submittals.

(3)

Although the paragraph states that informal dis-covery would commence after the November 9 meeting, agree-ment on such discovery has not been reached among the parties but will be discussed at that meeting.

(4)

As the paragraph acknowledges, a schedule for completion of the hearings could not be set, but the

LowEwTzis, NzwsAN. Reza & Axat. DAD Charles Bechhoefer, Esquire Dr. James C.

Lamb Ernest E. Hill Page Three October 14, 1981 parties and the Board discussed the mutual goal of com-pleting the expedited hearing by the end of March 1982.

1 Respectfully submitted, W

J ck R.

Newdan Of Counsel:

Lowenstein, Newman, Reis

& Axelrad 1025 Connecticut Avenue, NW Washington, D. C.

20036 Baker & Botts 3000 One Shell Plaza Houston, Texas 77002 Attorneys for HOUSTON LIGHTING & POWER COMPANY, Project Manager of the South Texas Project, act-ing herein on behalf of itself and the other Applicants, CITY OF SAN ANTONIO, TEXAS, acting by and through the city Public Service Board of the City of San Antonio, CENTRAL POWER AND. LIGHT COMPANY-and CITY OF AUSTIN, TEXAS.

cc:

Certificate of Service

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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HOUSTON LIGHTING AND POWER

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Docket Nos. 50-498 OL COMPANY ET AL.

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50-499 OL

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(South Texas Project,

)

Units 1 and 2)

)

i CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' letter signed by Jack R. Newman to the Atomic Safety and Licensing Board dated October 14, 1981, have teen served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, on this 14th day of October, 1981.

i Charles Bechhoefer, Esq.

Brian Berwick, Esq.

Chief Administrative Judge Assistant Attorney General 1

Atomic Safety and Licensing for the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Commission Division Washington, D.

C.

20555 P.O.

Box 12548, Capitol Station Austin, TX 78711 Dr. James C.

Lamb, III Administrative Judge William S.

Jordan, III, Esq.

313 Woodhaven Road Harmon & Weiss Chapel Hill, NC 27514 1725 I Street, NW Washington, D.

C.

20006 Ernest E.

Hill Administrative Judge Kim Eastman, Co-coordinator Lawrence Livermore Laboratory Barbara A.

Miller University of California Pat Coy P.O.

Box 808, L-123 Citizens Concerned About Livermore, CA 94550 Nuclear Power 5106 Casa Oro Mrs. Peggy Buchorn San Antonio, TX 78233 Executive Director Citizens for Equitable Lanny Sinkin Utilities, Inc.

2207-D Nueces Route 1, Box 1684

' Austin, TX 78705 Brazoria, TX 77422

Jay M. Gutierrez, Esq.

Office of the Executive Legal Director "U.S. Nuclear Regulatory Ccmmission Washington, D. C.

20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Decke' ting and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D. C.

20555

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