ML19347B383: Difference between revisions

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| number = ML19347B398
| number = ML19347B398
| issue date = 10/01/1980
| issue date = 10/01/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Impact of Plant on Waterfowl & Other Environ Effects.Line No Longer Extends Over Lake & Thus Does Not Need to Be Moved.Prof Qualifications Encl
| author name = Schlicht F
| author name = Schlicht F
| author affiliation = HOUSTON LIGHTING & POWER CO.
| author affiliation = HOUSTON LIGHTING & POWER CO.
Line 21: Line 21:
| number = ML19347B396
| number = ML19347B396
| issue date = 10/02/1980
| issue date = 10/02/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Response in Opposition to D Marrick 800911 Motion for Summary Disposition of Marrick Contention 2(c).Motion Lacks Statement of Facts or Admissible Evidence & Exceeds Scope of Contention.Certificate of Svc Encl
| author name = Copeland J, Newman J
| author name = Copeland J, Newman J
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
Line 36: Line 36:
| number = ML19347B394
| number = ML19347B394
| issue date = 09/11/1980
| issue date = 09/11/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Latching.In Order for Radioactive Emissions to Effect Electronics on Aircraft,Aircraft Would Have to Park at Site Boundary for Extended Period.Certificate of Svc Encl
| author name = Sumpter J
| author name = Sumpter J
| author affiliation = HOUSTON LIGHTING & POWER CO.
| author affiliation = HOUSTON LIGHTING & POWER CO.
Line 51: Line 51:
| number = ML19347B393
| number = ML19347B393
| issue date = 10/02/1980
| issue date = 10/02/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Response in Opposition to Tx Pirg Motion for Summary Disposition of Tx Pirg Addl Contention 50 Re Latching. Applicant Matl Statement of Undisputed Facts Remains Unchanged
| author name = Copeland J, Newman J
| author name = Copeland J, Newman J
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
Line 66: Line 66:
| number = ML19347B392
| number = ML19347B392
| issue date = 09/30/1980
| issue date = 09/30/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Economic Comparison Between Competing Generation Alternatives.Util Does Not Qualify for Any Exemptions to Fuel Use Act Which Would Allow Unlimited Use of Gas for Unlimited Time.W/Certificate of Svc
| author name = Buy J
| author name = Buy J
| author affiliation = HOUSTON LIGHTING & POWER CO.
| author affiliation = HOUSTON LIGHTING & POWER CO.
Line 81: Line 81:
| number = ML19347B390
| number = ML19347B390
| issue date = 09/29/1980
| issue date = 09/29/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Natural Gas Plant Alternative.Util Not Automatically Entitled to Fua Exemption Because No Nonattainment Areas Exist in Houston.No Environ Exemptions Available to Util
| author name = Mcguire W
| author name = Mcguire W
| author affiliation = HOUSTON LIGHTING & POWER CO.
| author affiliation = HOUSTON LIGHTING & POWER CO.
Line 96: Line 96:
| number = ML19347B389
| number = ML19347B389
| issue date = 10/02/1980
| issue date = 10/02/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Response in Opposition to Tx Pirg 800912 Motion for Summary Disposition of Tx Pirg Addl Contention 8 Re Natural Gas Alternative.As Matter of Law,Util Cannot Construct New Gas Fired Plants
| author name = Copeland J, Newman J
| author name = Copeland J, Newman J
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
Line 111: Line 111:
| number = ML19347B388
| number = ML19347B388
| issue date = 09/29/1980
| issue date = 09/29/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Sources of Groundwater for Facility.Lakes Conroe,Houston & Livingston Can Supply Surface Water to Meet City Demands Through Yr 2000.Curriculum Vitae,Excerpts of C Johnson & Saxion Depositions & Certificate of Svc Encl
| author name = Vansickle D
| author name = Vansickle D
| author affiliation = TURNER COLLIE & BRADEN, INC.
| author affiliation = TURNER COLLIE & BRADEN, INC.
Line 126: Line 126:
| number = ML19347B387
| number = ML19347B387
| issue date = 09/30/1980
| issue date = 09/30/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Site Evaluation.Util Analysis Looks Only to Cost,Not to Benefit.Curriculum Vitae Encl
| author name = Hussey J
| author name = Hussey J
| author affiliation = DAMES & MOORE
| author affiliation = DAMES & MOORE
Line 141: Line 141:
| number = ML19347B386
| number = ML19347B386
| issue date = 09/30/1980
| issue date = 09/30/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Affidavit Re Allens Creek Vs South Tx Project Sites.Cost Comparison Tabulation Encl
| author name = Mccuistion R
| author name = Mccuistion R
| author affiliation = HOUSTON LIGHTING & POWER CO.
| author affiliation = HOUSTON LIGHTING & POWER CO.
Line 156: Line 156:
| number = ML19347B385
| number = ML19347B385
| issue date = 10/02/1980
| issue date = 10/02/1980
| title = Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
| title = Response in Opposition to Tx Pirg Motion for Summary Disposition of Tx Pirg Contention 1 Re Site Comparison. Failure to Demonstrate Significance of Farmland pre-emption Is Fatal Defect.List of Remaining Issues in Dispute Encl
| author name = Copeland J, Newman J
| author name = Copeland J, Newman J
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
| author affiliation = BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL

Latest revision as of 00:09, 17 January 2020

Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
Date released: 12/27/2019 Download: ML19347B383
v • d • e


Affidavit Re Impact of Plant on Waterfowl & Other Environ Effects.Line No Longer Extends Over Lake & Thus Does Not Need to Be Moved.Prof Qualifications Encl
ML19347B398
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 10/01/1980
From: Schlicht F
HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B398 (20)
v • d • e
Response in Opposition to D Marrick 800911 Motion for Summary Disposition of Marrick Contention 2(c).Motion Lacks Statement of Facts or Admissible Evidence & Exceeds Scope of Contention.Certificate of Svc Encl
ML19347B396
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 10/02/1980
From: Copeland J, Newman J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
References
Download: ML19347B396 (14)
v • d • e
Affidavit Re Latching.In Order for Radioactive Emissions to Effect Electronics on Aircraft,Aircraft Would Have to Park at Site Boundary for Extended Period.Certificate of Svc Encl
ML19347B394
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/11/1980
From: Sumpter J
HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B394 (16)
v • d • e
Response in Opposition to Tx Pirg Motion for Summary Disposition of Tx Pirg Addl Contention 50 Re Latching. Applicant Matl Statement of Undisputed Facts Remains Unchanged
ML19347B393
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 10/02/1980
From: Copeland J, Newman J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
References
Download: ML19347B393 (13)
v • d • e
Affidavit Re Economic Comparison Between Competing Generation Alternatives.Util Does Not Qualify for Any Exemptions to Fuel Use Act Which Would Allow Unlimited Use of Gas for Unlimited Time.W/Certificate of Svc
ML19347B392
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/30/1980
From: Buy J
HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B392 (10)
v • d • e
Affidavit Re Natural Gas Plant Alternative.Util Not Automatically Entitled to Fua Exemption Because No Nonattainment Areas Exist in Houston.No Environ Exemptions Available to Util
ML19347B390
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/29/1980
From: Mcguire W
HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B390 (5)
v • d • e
Response in Opposition to Tx Pirg 800912 Motion for Summary Disposition of Tx Pirg Addl Contention 8 Re Natural Gas Alternative.As Matter of Law,Util Cannot Construct New Gas Fired Plants
ML19347B389
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 10/02/1980
From: Copeland J, Newman J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
References
Download: ML19347B389 (8)
v • d • e
Affidavit Re Sources of Groundwater for Facility.Lakes Conroe,Houston & Livingston Can Supply Surface Water to Meet City Demands Through Yr 2000.Curriculum Vitae,Excerpts of C Johnson & Saxion Depositions & Certificate of Svc Encl
ML19347B388
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/29/1980
From: Vansickle D
TURNER COLLIE & BRADEN, INC.
To:
References
Download: ML19347B388 (44)
v • d • e
Affidavit Re Site Evaluation.Util Analysis Looks Only to Cost,Not to Benefit.Curriculum Vitae Encl
ML19347B387
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/30/1980
From: Hussey J
DAMES & MOORE
To:
References
Download: ML19347B387 (12)
v • d • e
Affidavit Re Allens Creek Vs South Tx Project Sites.Cost Comparison Tabulation Encl
ML19347B386
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/30/1980
From: Mccuistion R
HOUSTON LIGHTING & POWER CO.
To:
References
Download: ML19347B386 (12)
v • d • e
Response in Opposition to Tx Pirg Motion for Summary Disposition of Tx Pirg Contention 1 Re Site Comparison. Failure to Demonstrate Significance of Farmland pre-emption Is Fatal Defect.List of Remaining Issues in Dispute Encl
ML19347B385
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 10/02/1980
From: Copeland J, Newman J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
References
Download: ML19347B385 (18)
v • d • e
Memorandum of Law Supporting Applicant Responses to Tx Pirg 800806 & 0916 & D Marrack 800911 Motions for Summary Disposition.Intervenors' Failure to Establish All Evidence Leads to Irrefutable Conclusion.Certificate of Svc Encl
ML19347B382
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 10/02/1980
From: Copeland J, Newman J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
References
Download: ML19347B382 (13)
v • d • e
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