ML20039B488

Fourth Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl

ML20039B488
Person / Time
Site:	South Texas
Issue date:	12/21/1981
From:	Gutterman A JOINT APPLICANTS - SOUTH TEXAS PROJECT, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	CITIZENS FOR EQUITABLE UTILITIES
References
ISSUANCES-OL, NUDOCS 8112230113
Download: ML20039B488 (4)

Text

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D XKETED UNITED STATES OF AMERICA USNN

[- NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING Bdab OE0 M E G

_ g,c h CEE TM In the Matter of ) 6: m imG & SERvic]t

) ERAliCH HOUSTON LIGHTING AND POWER ) Docket Nos. 50-498 OL COMPANY, -ET AL. ) 50-499 OL

)

(South Texas Project, )

Units 1 and 2) ) December 21, 1981 APPLICANTS' FOURTH SET OF-INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CEU Pursuant to the Licensing Board's Fourth Prehearing Conference Order and Sections 2.740b and 2.741 of the Nuclear Regulatory Commission's Rules of Practice, Applicants propound the following Interrogatories and Requests for Production of Documents to Citizens for Equitable Utilities (herinafter "CEU"). Applicants incorporate herein the instructions and definitions set forth in their First' Set of Interrogatories and Requests for Production of Documents to CEU.

l 1

These Interrogatories and Requests for Production of Documents seek information related to contentions 1.8(a-d),

concerning I&E Report 81-28, as admitted into controversy by the Fourth Prehearing Conference Order. Contentions 1.8(a-d) were identified as contentions 23, 24, 25 and 26 in Citizens.

Concerned About Nuclear Power Motion to File Additional Contentions Based on New Information and to Establish'A Discovery and Hearing Schedule with Respect to New Contentions. z )fC[$

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.2-e Interrogatories and Sequests for Production 4 of Documents (1) Identify each of the. documents, including but not limited to tape recordings, and other sources of information (other than ~ I&E Report 81-28) upon which CEU relies for support of contentions 1.8(a-d) Lor which constitute'.a source of information for CEU concerning such contentions.

(2) Produce for inspection and copying each document identified in the response to Interrogatory 1.

Respectfully submitted, I

AL: /thw Jack-R. Newman

-Maurice Axelrad-Alvin'H. Gutterman 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Finis E. Cowan Thomas B. Hudson 3000 One Shell' Plaza Houston, TX 77002 Dated: December 21, 1981 Attorneys for HOUSTON LIGHTING

& POWER COMPANY, Project Manager LOWENSTEIN, NEWMAN, REIS of the South Texas Project

& AXELRAD acting herein on behalflof itself 1025 Connecticut Ave., N.W. and the other Applicants,-THE Washington, D.C. 20036 CITY OF SAN ANTONIO, TEXAS, acting by and through the City BAKER & BOTTS Public Service Board of the City 3000 One Shell Plaza of San Antonio, CENTRAL POWER Houston, TX 77002 AND LIGHT COMPANY and CITY OF AUSTIN, TEXAS

.- . - . ~ . . .

F UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

.In the Matter of )

)

HOUSTON LIGHTING AND POWER ) Docket Nos. 50-498 OL COMPANY, -ET AL. ) 50-499 OL

)

(South Texas Project, )

Units 2 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' Fourth Set of

, Interrogatories and Requests for Production of Documents to CEU have been served on the following individuals and enti-ties by deposit in the United States mail, first class, postage prepaid, or as indicated by footnote, on this 21st day of December, 1981.

Charles Bechhoefer, Esq. Brian Berwick, Esq.

Chief Administrative Judge Assistant Attorney General 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, N.W.

Washington, D.C. 20006

[ Ernest E. Hill Administrative Judge Kim Eastman, Co-coordinator Lawrence Livermore Laboratory Barbara A. Miller University of California Pat Coy l P.O. Box 808, L-46 Citizens Concerned About Livermore, CA 94550 Nuclear Power l 5106 Casa Oro l

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 Federal Express

• • Hand Delivery I

Jay M. Gutierrez, Esq.

Office of the E A ecutive

. Legal _ Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

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

[ Washington, D.C. 20555 Docketing and Service Section Office of the Secretary

U.S. Nuclear Regulatory Commission ,,

Washington, D.C. 20555

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