ML20037C341
| ML20037C341 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/03/1981 |
| From: | Gutierrez J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8102040423 | |
| Download: ML20037C341 (4) | |
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02/03/81
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UNITED STATES OF AMERICA 9 0 NUCLEAR REGULATORY COMMISSION
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p go p, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s
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In the Matter of
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Houston Lighting & Power Company,
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Docket Nos. 50-498 0.8..
et al.
50-499 0.L.
(South Texas Project, Uaits 1 and 2)
)
STAFF RESPONSE TO APPLICANT'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE MOTIONS TO COMPEL ANSWERS TO INTERR0GATORIES On January 16, 1981, Houston Lighting & Power Company (hereinafter referred to as the Applicant) served its motion, requesting that the dead-line for the filing of motions to compel discovery be extended from Janu-ary 16,1981, until 10 days following Applicant's receipt of discovery material previously requested from Citizens Concerned About Nuclear Power, Inc. and Citizens For Equitable Utilities, Inc. (hereinafter referred to as 1
i CCANP and CEU, respectively).
In the alternative, and in the event that the Board denied the requested extension, the Applicant prayed that the Board (1) grant its motions to compel discovery previously filed April 15, 1980 and May 8, 1980, but as yet not ruled upon; (2) compel CCANP to produce n
documents which were infonnally requested by letter dated July 7,1980; and (3) compel CCANP and CEU to respond to interrogatories served by Applicant 1
on December 5,1980.
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. As set forth in the Applicant's motion, both CEU and CCANP have indi-cated to the Applicant a willingness to,nrovide the information requested; however, the Applicant reached the filing deadline for motions to compel discovery without receiving the Intervenor's answers and further without knowing what inforr.ation the Intervenors m) _ht subsequently provide.
Con-fronted with this procedural dilemma, the Applicant chose to both request an extension of time for filing motions to compel discovery and, in the alterna-tive, move to compel the Intervenors to respond to various discovery requests outstanding.
It appears to the Staff that both CCANP and CEV have indicated to the Applicant a willingness to provide the requested information, and it further appears that the granting of the Applicant's motion for an extension will not adversely impact upon the hearing schedule, as set forth in the Board's Second Prehearing Conference Order of December 2,1980.
Accordingly, the Staff does not oppose Applicant's motion for an extension of time in which to file motions to compel answers to interrogatories and other discovery material.
l Respectfully submitted, j{.CCC-
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ay M. Gutierrez Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of February, 1981.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & 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
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and 2)
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NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the captioned matter.
In accordance with 52.713,10 C.F.R. Part 2, the following information is provided:
Name
- Jay M. Gutierrez Address
- Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Telephone' Number
- Area Code 301-432-7991 Admissions
- Supreme Court for the State of West Virginia District Court for the Northern and Southern Districts of-West Virginia Name of Party
- NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C.
20555 g lk -
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.Jaf M. Gutierrez v
LCounsel for4RC Staff Dated at Bethesda, Maryland this 3rd day of February,1981.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING AND POWER COMPANY,
)
)
50-499
)
(South Texas Project, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " STAFF RESPONSE TO APPLICANT'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE MOTIONS TO COMPEL ANSWERS TO INTERROGATORIES" and " NOTICE OF APPEARANCE" of Jay M. Gutierrez in the above-captioned pro-ceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 3rd day of February, 1981:
Charles Bechhoefer, Esq., Chairman
- Brian Berwick, Esq.
Atomic Safety and Licensing Board Assistant Attorney General Panel Environmental Protection Division U.S. Nuclear Regulatory Comission P.O. Box 12548, Capitol Station Washington, D.C.
20555 Austin, TX 78711 Dr. James C. Lamb, III Jack R. Newman, Esq.
313 Woodhaven Road Lowenstein, Newman, Reis, Chapel Hill, NC 27514 Axelrad & Toll 1025 Connecticut Avenue, N.W.
Dr. Emmeth A. Luebke*
Washington, D.C.
20036 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing board U.S. Nuclear Regulatory Commission Panel
- Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Melbert Schwarz, Jr., Esq.
l Baker and Botts Atomic Safety and Licensing Appeal l
One Shell Plaza Panel
- l Houston, TX 77002 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 l
Mrs. Peggy Buchorn l
Executive Director Docketing and Service Section*
Citizens for Equitable Utilities, Inc.
Office of the Secretary Route 1, Box 1684 U.S. Nuclear Regulatory Comission Brazoria, TX 77422 Washington, D.C.
20555 l
l Kim Eastman, Co-coordinatcr Betty Wheeler, Esq.
Barbara A. Miller Tim Hoffman, Esq.
I Pat Coy Hoffman, Steeg & Wheeler Citizens Concerned About Nuclear 1008 S. Madison Power Amarillo, TX 79101 5106 Casa Oro San Antonio, TX 78233 l
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WatM.Guti.errez Counsel for'hRC Staff