ML20083K470

Forwards Corrected Pages of Interrogatories That Erroneously Referred to Licensee.Document Title Should Be Corrected Initial Interrogatories to & First Request for Production of Documents by Central Power & Light Co

ML20083K470
Person / Time
Site:	South Texas
Issue date:	01/08/1979
From:	Poirier M SPIEGEL & MCDIARMID
To:	Mark Miller, Racquel Powell, Stahl D ISHAM, LINCOLN & BEALE
References
NUDOCS 7901300022
Download: ML20083K470 (1)

Text

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( i law orrtCts SPIEGEL & McDIAn.snD 2600 VIRGINIA AVENUE. N.W.

WASHINGTCN. D.C. 20037 ctCR3r sP:EGEL TELEPMC E#202) 33 m oo

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ACBERT C. MCDI ARMlO TELtCCPitR (202) 33b2974 ROBERT HARLEY ttAR S ANDR A J. sTREast TMCues C. TRAcotR ROttRT A. JASLCN JCMN MICMAEL ADR AGNA JAMES N. MCRWOCD CYNTM1 A s. BCGCR AC ALAN J. RCTH ,

rRANCts E. rRANCis vanuarf 8,1978 s uassACMustMs sae cmLvl

.ARy J. NEwtu.

DANitL 1. DAVIDSON MARC R. PCIRitR THEM AS N. McHUGH. JR.

CAN14,L J. GUTTMAN O FETrn K. MATT ,

DAVID R. STRAUS Michael I. Miller, Esq.

Richard E. Pcwell, Esq.

David M. Ste.hl, Esq.

E cras G. Ptfan, Esq.

Isham, Lincoln & Beale One* First National Pla::a Chicago, Illinois 60603 Pe: Houston Lichting and Power Co., et al.

(South 'IP.xas Project, Units No.1 and 2) ,

NFC Docket Ncs. 50-498A and 50-499A)

Gentlemen:

On Januarf 5,1979, the Public Utilities Board of the City of

.Brownsville, Texas, sent you corrected initial interrogatories and a request for producti'en of doct:nents in the above-captiened proceeding.

This doctrent was erroneously entitled " Corrected Initial Interroga-terits to, and First. Request for Production of Docunents by Houston Lighting

& Power C g Tf frcm the Pt:blic Utilities Board of the City of Brownsville, Texas." he Data Pequest was intended to be addressed to Central Power

& Light Ccrpany and the title should so reflect. Please substitute the corrected pages ene and nine enclosed for those pages in the inh erogatories and request for documents sent you en January 5,1979.

We regret any inconvien this may have caused you.

Very truly yours, b' (M (.'. W Marc R. Poirier Attorney for the Public Utilities Board of the City of Brcwnsvillo c Texas cc w/enicosure: All Parties '

( OClf 5 -

Uy~'ED STATES OF AMERICA (

. BEFORE THE NUCLEAR REGULATORY COMMISSION .

l l

. In the Matter of Ecuston Lighting & Power Company )

The City of San Antonio )

The City of Austin ) Docket Nos . 50-498 A Central Power & Light Company ) and 50-499k (South Texas Project, Units )

No. 1 & No. 2) )

CORRECTED INITIAL INTERROGATORIES TO AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS BY CENTRAL POWER & LIGHT COMPANY FROM THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE, TEXAS -

Pursuant to Sections 2.740, 2.740(b) and 2.741 of the Nucl, ear Regulatory Commission's Rules of Practice under the Atomic Energy Act, the Public Utilities Board of the City of ,

, Brownsville, Texas ("Brownsville") hereby files initial interrogatories to and requests the production of doc'uments by Central Power & Light Company ("CP&L").

I.- GENERAL ~ INSTRUCTIONS

1. Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person (or persons) making it.

3 2 '. Each document produced in response to this request should be re'ferenced with the r. umber ( )' 'of ' the relevant

~

, request and subsection, if'any. Should any of ~ the -documents- .

requested pursuant to this set of interrogatories and i

requests for document production have already been made available for Brownsville's inspection,~it will .id suf-ficient to note this ' fact and to provide .the following

-information: (1). document production number, if f any; (2) i

1

< i l 9- I tic:c. or assets of which have been acquired by' CSW.

T. " Texas Utilities" or "TU" shall mean Texas Utilities Generating Company,.its parent, affiliated, direct and

. indirect subsidiary and all predecessor companies, including, but not limited to,' Texas Utilities Company, Dallas Power &

Light Company, Texas Electric Service Ccmpany and Texas Power

& Light Company.

U. " South Texas Units" shall be understood to refer to the nuclear generating units for which applicants in the above-captioned proceeding hold construction permits issued by the Nuclear Regulatory Commission.

III. DOCUMENTS NO LONGER IN CP&L'S POSSESSION, CUSTODY, OR CONTROL: .

If any document otherwise responsive to any request was, on'or after December 19, 1970 (date of enactment of P. L.91-560), but is no longer in CP&L's possession, or subject to CP&L's control, or in existence, state whether (1) it is missing or lost, (2) has been destroyed, (3) has been trans-ferred voluntarily to others, or'(4) has been otherwise disposed of. In each instance, explain the circumstances surrounding such disposition and identi~fy the person (s) directing or authorizing its destruction or transfer, and the date(s) of such direction or authorization. . Identify each

such document by listing its author and addressee, type (e.g., letter', memorandum, telegram, chart, photograph, etc.), date, subject matter, whether the document . (or copies) are still in existence, and if so, their present location (s) e