ML20069B835

Motion to Conduct Prehearing Conference,In View of Info Made Available to Parties in Bechtel Rept EN-619 & IE Repts 82-02 & 82-12,in Order to Clarify Issues,Discuss Stipulations & Set Schedule for Filing Motions.Certificate of Svc Encl

ML20069B835
Person / Time
Site:	South Texas
Issue date:	03/14/1983
From:	Newman J HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8303170283
Download: ML20069B835 (4)

Text

-

LD.KETED UNITED STATES OF AMERICA '*'^

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA MR 15 N1:24 In the Matter of ) - hn: it :

~a & SEPV U'

) 2 RANCH HOUSTON LIGHTING AND POWER )

COMPANY, ET AL. Docket Nos. STN 50-498 OL

) STN 50-499 OL

)

(South Texas Project, )

Units 1 and 2) )

Applicants' Motion for Prehearing Conference Applicants move the Board to conduct a prehearing con-ference at the Board's earliest convenience. The Board's Memorandum dated June 24, 1982 adopted the schedule agreed upon by the parties at Tr. 10664-67, which contemplates a prehearing conference approximately 60 days after the commencement of dis-covery.

Discovery began with the service of the Staff's report on the Quadrex findings (I&E Report 82-12) on January 17, 1983 and the 60th day is in mid-March.

In view of the substantial amount of information that has been made available to the parties in the Bechtel report (EN-619) and the two NRC Staff I&E Reports (82-02 and 82-12), a pre-nearing conference would be particularly appropriate to simplify and clarify the issues, discuss stipulations and admissions of fact, and set a schedule for filing of motions for summary disposition, identification of exhibits and wit-nesses, filing of testimony and the evidentiary hearing. Should there arise issues among the parties regarding discovery mat-ters, they too could be addressed at the prehearing conference.

BOO 31f0203 830314

ra ^"" "" #M 9 06

. . Applicants' counsel has discussed the schedule for the prehearing conference with counsel for the NRC Staff and Mr.

Sinkin.

NRC Staff counsel has no schedule conflicts within the next few weeks.

Mr. Sinkin stated that because of other com-mitments he will be unable to participate in a prehearing con-ference during the week of March 21, but is otherwise available during the next few weeks. Applicants are prepared to parti-cipate in a prehearing conference at the Board's convenience, and urge the setting of the earliest possible date consistent with the personal schedules of the Board members and the availability of representatives for the other parties, as ,

described above.

Respectfully submitted,

/

/ Jack R. Newmar(

W Maurice Axelrad Alvin H. Gutterman Donald J. Silverman 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Finis E. Cowan Thomas B. Hudson, Jr.

3000 One Shell Plaza Houston, Texas 77002 Dated: March 14, 1983 ATTORNEYS FOR HOUSTON LIGHTING LOWENSTEIN, NEWMAN, REIS & POWER COMPANY, Project' Manager

& AXELRAD, P.C. of the South Texa1 Project acting 1025 Connecticut Avenue, herein on behalf of itself and N.W.

the other Applicants, THE CITY OF Washington, SAN ANTONIO, TEXAS, acting by and D.C. 20036 through the City Public Service BAKER & BOTTS Board of the City of San Antonio, CENTRAL POWER AND LIGHT COMPANY, 3000 One Shell Plaza and CITY OF AUSTIN, TEXAS Houston, Texas 77002

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

HOUSTON LIGHTING & POWER )

COMPANY, E_T _AL. Docket Nos. 50-498 OL

) 50-499 OL (South Texas Project, Units 1 )

and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' Motion for Prehearing Conference dated March 14, 1983, have been served in on the the U.S. following Hail, individuals and entities by deposit first class, postage prepaid on this 14th day of March, 1983.

Charles Bechhoefer, Esq. Brian Berwick, Esq.

Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel U.S. Nuclear Regulatory Environmental Protection Division Commission 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 1725 I Street, N.W.

27514 Washington, D.C. 20006 Ernest E. Hill Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller Lawrence Livermore Laboratory Pat Coy University of California P.O. Box 808, L-46 Citizens Concerned About Livermore, CA 94550 Nuclear Power 5106 Casa Oro San Antonio, TX 78233 Mrs. Peggy Buchorn Executive Director Lanny Sinkin Citizens for Equitable 2207-D Nueces Utilities, Inc. Austin, TX Route 1, Box 1684 78705 Brazoria, TX 77422 Robert G. Perlis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

e Jp ' 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 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

/ '

2D f// '

'/

,__....__,__.,_,,__,_____,__..,._,,._._.m . , _ _ - ,_ . . , , _ , . _ . _ , _ _ _ _ . . , _ , _ _ ,

_ . . _ _ . . . . . . _ . . . . _ _ . , _ _ . _ , .