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| RECEIPT OF SUBJECT DOCUMENT BY MAIL ON b7-79. CEU STILL VAS VAITING. | | RECEIPT OF SUBJECT DOCUMENT BY MAIL ON b7-79. CEU STILL VAS VAITING. |
| ON APRIL 12, 1979, NINE DAYS AFTER THE DATE OF TE ORDER, MRS. BUCHORN CALIED MR. H. J. McGURREN, NRC COUNSEL. MR. McGURREN ASSURED MRS. BUCHORN THAT INDEED THERE HAD BEEN A DECISION AND THAT CEU HAD BEEN GRAFTED INTER-VENTION AND TWO CONIENTIONS. MRS. BUCHORN STAIED TO MR. McGURREN THAT SHE HAD NOF RECEIVED NOTIFICATION BY MAIL AND THAT IT VAS IMPOSSIBIE TO REPLY TO SOMETHING THAT HAD Nor BEEN SEEN. MR. McGURREN ASSUBED MRS. BUCHORN THAT A COPT OF THE ORDER VOULD BE PIACED IN THE MAIL THE FOLLOWING MORNING,bl3-79. | | ON APRIL 12, 1979, NINE DAYS AFTER THE DATE OF TE ORDER, MRS. BUCHORN CALIED MR. H. J. McGURREN, NRC COUNSEL. MR. McGURREN ASSURED MRS. BUCHORN THAT INDEED THERE HAD BEEN A DECISION AND THAT CEU HAD BEEN GRAFTED INTER-VENTION AND TWO CONIENTIONS. MRS. BUCHORN STAIED TO MR. McGURREN THAT SHE HAD NOF RECEIVED NOTIFICATION BY MAIL AND THAT IT VAS IMPOSSIBIE TO REPLY TO SOMETHING THAT HAD Nor BEEN SEEN. MR. McGURREN ASSUBED MRS. BUCHORN THAT A COPT OF THE ORDER VOULD BE PIACED IN THE MAIL THE FOLLOWING MORNING,bl3-79. |
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| TE PROBEM. MR. SEPENS STATED THAT HE WOULD INVESTIGNIS AND CALL MRS. | | TE PROBEM. MR. SEPENS STATED THAT HE WOULD INVESTIGNIS AND CALL MRS. |
| BUCHORN LATER. SHORTLY TEREAFER MR. STEPHENS CALED MRS. BUCHORN. AND SAID THAT IT WAS TEIR FAULT THAT THE ORDER HAD NCfr BEEN MAILED. haS. BUCHORN TEN ASED HOW MANY ITEMS HAD NOT BEEN MAIED AND MR. SEPHENS SAID THFRE WERE POSSIBLY OTERS AISO. MRS. BU/: HORN T.EN SAID THAT SE V00LD PREPARE A M0rION FOR A CONTINUANCE AND MR. STEPHENS STATED THAT TE REQUEST WAS PROER UNDER TE CIRCUMSTANCES AND THAT E WOULD CALL MR. BEC20EFER AND ADVISE HIM OF TE PROBLEM. | | BUCHORN LATER. SHORTLY TEREAFER MR. STEPHENS CALED MRS. BUCHORN. AND SAID THAT IT WAS TEIR FAULT THAT THE ORDER HAD NCfr BEEN MAILED. haS. BUCHORN TEN ASED HOW MANY ITEMS HAD NOT BEEN MAIED AND MR. SEPHENS SAID THFRE WERE POSSIBLY OTERS AISO. MRS. BU/: HORN T.EN SAID THAT SE V00LD PREPARE A M0rION FOR A CONTINUANCE AND MR. STEPHENS STATED THAT TE REQUEST WAS PROER UNDER TE CIRCUMSTANCES AND THAT E WOULD CALL MR. BEC20EFER AND ADVISE HIM OF TE PROBLEM. |
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| ROUTE 1 BOX 432 BRAZCRIA, TEXAS, 77422 2233 071 3. | | ROUTE 1 BOX 432 BRAZCRIA, TEXAS, 77422 2233 071 3. |
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| UNITED STAIES OF AMERICA NUCLEAS REGUIATORY C mMISSION BEFOE TE ATOMIC SAFETY AND LICENSING BOARD h | | UNITED STAIES OF AMERICA NUCLEAS REGUIATORY C mMISSION BEFOE TE ATOMIC SAFETY AND LICENSING BOARD h |
| IN TE MATIER 07 HCUSTON LIGHTING AND F0WER DOCKET NOS. 5 M 98 COMPANT, ET AL. h S M 99 (SourH TEXAS PROJECT, UNITS 1 & 2) o i | | IN TE MATIER 07 HCUSTON LIGHTING AND F0WER DOCKET NOS. 5 M 98 COMPANT, ET AL. h S M 99 (SourH TEXAS PROJECT, UNITS 1 & 2) o i |
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| CHARLES ECHMCEFER, ESQ., CHAIRM ATWIC SAFETT AND LICENSING BOARD U. S. NUCIEAR REGUIAT0itY COMMISSION WASHINGTON, D. C. 2e555 DR. JAMES C. LAMB, III 313 WOODHAVEN ROAD CHAPEL HILL, NORTH CAROLINA 27514 DR. EMMETH A. LUE3XE ATmIC SAFETT AND LICENSING BOARD U. S. NUCIEAR REGUIATORI CCHMISSION VASHINGTON, D. C. 2e555 ENRY J. McGURREN, ESQUIRE EARING AITORNET OFFICE OF TE EXECUTIVE IEGAL DIRECTOR U. S. NUCIEAR REGULATORY CCHMISION VASHINGTON, D. C. 20555 RICHARD V, LOERRE, ESQUIRE ASSISTANT ATTORNET GENERAL, STATE OF TEXAS P. O. BOX 12548 CAPITOL STATION AUSTIN, TEXAS 78711 2233 072 bl [kN[4[ | | CHARLES ECHMCEFER, ESQ., CHAIRM ATWIC SAFETT AND LICENSING BOARD U. S. NUCIEAR REGUIAT0itY COMMISSION WASHINGTON, D. C. 2e555 DR. JAMES C. LAMB, III 313 WOODHAVEN ROAD CHAPEL HILL, NORTH CAROLINA 27514 DR. EMMETH A. LUE3XE ATmIC SAFETT AND LICENSING BOARD U. S. NUCIEAR REGUIATORI CCHMISSION VASHINGTON, D. C. 2e555 ENRY J. McGURREN, ESQUIRE EARING AITORNET OFFICE OF TE EXECUTIVE IEGAL DIRECTOR U. S. NUCIEAR REGULATORY CCHMISION VASHINGTON, D. C. 20555 RICHARD V, LOERRE, ESQUIRE ASSISTANT ATTORNET GENERAL, STATE OF TEXAS P. O. BOX 12548 CAPITOL STATION AUSTIN, TEXAS 78711 2233 072 bl [kN[4[ |
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| HONORABLE EURT O'CONELL COUNTT JUDCE, MATAGORDA COUNTY MATAGORDA COUNTY COURT HOUSE BAT CITY, TEXAS 77414 B. GORDON GOOCH, ESQUIE 1741 ENNSTLVANIA AVENUE, N. V. | | HONORABLE EURT O'CONELL COUNTT JUDCE, MATAGORDA COUNTY MATAGORDA COUNTY COURT HOUSE BAT CITY, TEXAS 77414 B. GORDON GOOCH, ESQUIE 1741 ENNSTLVANIA AVENUE, N. V. |
| VASHINGTON, D. C. 24646 MR. IANNY SINKIN CITIZENS CONCERED ASCUT NUCLEAR POWER 838 E. MAGNOLIA SAN ANTONIO, TEIAS 78212 MR. DAVID MARIE 39 M VAREHOUSE ROV SUITE C AUSTIN, TEXAS 7876 AUSTIN CITIZENS FOR ECONOMICAL EERGY HR. ROGER DUNCAN 961 VEST 241h STEET AUSTIN, TEXAS 78705 ATOMIC SAFETT AND LICENSING APEAL BOARD U. S. NUCIEAR REGULATORY CClotISSION VASHINGTON, D. C. 28555 VR CHASE R. STEPENS DOCKETING AND SZHVICE SECTION . | | VASHINGTON, D. C. 24646 MR. IANNY SINKIN CITIZENS CONCERED ASCUT NUCLEAR POWER 838 E. MAGNOLIA SAN ANTONIO, TEIAS 78212 MR. DAVID MARIE 39 M VAREHOUSE ROV SUITE C AUSTIN, TEXAS 7876 AUSTIN CITIZENS FOR ECONOMICAL EERGY HR. ROGER DUNCAN 961 VEST 241h STEET AUSTIN, TEXAS 78705 ATOMIC SAFETT AND LICENSING APEAL BOARD U. S. NUCIEAR REGULATORY CClotISSION VASHINGTON, D. C. 28555 VR CHASE R. STEPENS DOCKETING AND SZHVICE SECTION . |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ST-HL-AE-4162, Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses1992-07-22022 July 1992 Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses ST-HL-AE-4146, Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants1992-07-0606 July 1992 Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants ST-HL-AE-4145, Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule1992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule ML20101K1131992-06-29029 June 1992 Motion for Leave to Suppl Motion to Modify or Quash Subpoenas & Supplemental Info.* OI Policy Unfair & Violative of Subpoenaed Individuals Statutory Rights & Goes Beyond Investigatory Authority.W/Certificate of Svc ML20101G2041992-06-18018 June 1992 Motion to Modify or Quash Subpoenas.* Requests Mod of Subpoenas Due to Manner in Which Ofc of Investigations Seeks to Enforce Is Unreasonable & Fails to Protect Statutory Rights of Subpoenaed Individuals.W/Certificate of Svc ML20087L3301992-04-0202 April 1992 Affidavit of RW Cink Re Speakout Program ML20087L3491992-04-0202 April 1992 Affidavit of JW Hinson Re ATI Career Training Ctr ML20087L3651992-04-0202 April 1992 Affidavit of Rl Balcom Re Access Authorization Program ML20087L3561992-04-0202 April 1992 Affidavit of Wj Jump Re Tj Saporito 2.206 Petition ML20116F2671992-02-19019 February 1992 Requests NRC to Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility ML20094E9511992-02-10010 February 1992 Requests That NRC Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility & to Adequately Train All Util Employees in Use of Rev 3 to Work Process Program ML20066C5041990-09-24024 September 1990 Comment on Proposed Rule 10CFR26 Re NRC Fitness for Duty Program.Urges NRC Examine Rept Filed by Bay City,Tx Woman Who Was Fired from Clerical Position at Nuclear Power Plant Due to Faulty Drug Test Administered by Util ML20006A0281990-01-0808 January 1990 J Corder Response to NRC Staff Motion to Modify Subpoena & Motion for Protective Order.* Requests Protective Order Until NRC Makes Documents Available to Corder by FOIA or Directly.W/Certificate of Svc ML20005G1431989-12-11011 December 1989 Motion to Modify Subpoena & Motion for Protective Order.* Protective Order Requested on Basis That Subpoena Will Impose Undue Financial Hardship on J Corder ML20005G1451989-12-0505 December 1989 Affidavit of Financial Hardship.* Requests NRC to Provide Funds for Investigation & Correction of Errors at Plant Due to Listed Reasons,Including Corder State of Tx Unemployment Compensation Defunct ST-HL-AE-3164, Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components1989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20205T7001988-11-0101 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Initiation of Fitness for Duty Program at Facility.Need for Program Based on Presumption That Nuclear Power Activities Require That Personnel Be Free from Impairment of Illegal Drugs ML20151M2071988-07-25025 July 1988 Comment Supporting Proposed Rules 10CFR170 & 171 Re Fee Schedules.Principal Objection to Rules Relates to Removal of Current Ceilings on Collection of Fees ML20196A3701988-06-17017 June 1988 Notice of Receipt of Petition for Director'S Decision Under 10CFR2.206 & Issuance of Director'S Decision Denying Petitioners Request DD-88-09, Decision DD-88-09 Denying 880317 Petition by Earth First, Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign & Travis County Democratic Women Committee for Commission to Delay Util Licensing Vote1988-06-17017 June 1988 Decision DD-88-09 Denying 880317 Petition by Earth First, Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign & Travis County Democratic Women Committee for Commission to Delay Util Licensing Vote ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20150D1401988-03-21021 March 1988 Appeal of Director'S Decision on Southern Texas Project.* Requests That Commission Consider Appeal & Stay Licensing Decision Until Sufficient Evidence Acquired to Support Final Decision ML20150D0411988-03-17017 March 1988 Petition Of:Earth First!,Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign, Travis County Democratic Women'S Committee.* Withholding of Issuance of License Requested ML20196H4661988-02-29029 February 1988 Receipt of Petition for Director'S Decision Under 10CFR2.206.* Gap 880126 Petition to Delay Voting on Full Power OL for Facility Until Investigation of All Allegations Completed Being Treated,Per 10CFR2.206 ML20148Q9531988-01-26026 January 1988 Petition of Gap.* Commission Should Delay Vote on Licensing of Facility Until Thorough Investigation of All Allegations Completed & Public Rept Issued.Exhibits Encl ML20237C2751987-12-13013 December 1987 Director'S Decision 87-20 Denying Petitioners 870529 Motion That Record in Facility Licensing Hearings Be Reopened & Fuel Loading Be Suspended Pending Resolution of Issues. Petitioner Failed to Provide Any New Evidence ML20236H3751987-10-29029 October 1987 NRC Staff Consent to Motion to Quash Subpoena Filed by E Stites.* Staff Concedes Possibility of Deficiencies in Svc of Subpoena to Stites & Therefore Does Not Oppose Motion to Quash.Certificate of Svc Encl ML20236E0111987-10-23023 October 1987 Order.* Grants NRC Request for Addl Time to Respond to Motion to Quash Subpoena of E Stites,Per 871008 Order. Response Should Be Filed by 871029.Served on 871023 ML20235T3891987-10-0808 October 1987 Motion to Quash Subpoena & Motion for Protective Order.* Subpoena Issued by Rd Martin on 870922 Should Be Quashed Due to Stites Not Properly Served,Witness Fees & Transportation Costs Not Provided & Issuance in Bad Faith ML20235T4171987-10-0808 October 1987 Memorandum in Support of Motion to Quash or in Alternative in Support of Motion for Protective Order.* Martin 870922 Subpoena of Stites Invalid & Improper.Decision to Subpoena at Late Date Form of Harassment.W/Certificate of Svc ML20195D8561987-09-22022 September 1987 Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant IA-87-745, Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant1987-09-22022 September 1987 Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant 1999-05-04
[Table view] Category:PLEADINGS
MONTHYEARML20101K1131992-06-29029 June 1992 Motion for Leave to Suppl Motion to Modify or Quash Subpoenas & Supplemental Info.* OI Policy Unfair & Violative of Subpoenaed Individuals Statutory Rights & Goes Beyond Investigatory Authority.W/Certificate of Svc ML20101G2041992-06-18018 June 1992 Motion to Modify or Quash Subpoenas.* Requests Mod of Subpoenas Due to Manner in Which Ofc of Investigations Seeks to Enforce Is Unreasonable & Fails to Protect Statutory Rights of Subpoenaed Individuals.W/Certificate of Svc ML20116F2671992-02-19019 February 1992 Requests NRC to Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility ML20094E9511992-02-10010 February 1992 Requests That NRC Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility & to Adequately Train All Util Employees in Use of Rev 3 to Work Process Program ML20006A0281990-01-0808 January 1990 J Corder Response to NRC Staff Motion to Modify Subpoena & Motion for Protective Order.* Requests Protective Order Until NRC Makes Documents Available to Corder by FOIA or Directly.W/Certificate of Svc ML20005G1431989-12-11011 December 1989 Motion to Modify Subpoena & Motion for Protective Order.* Protective Order Requested on Basis That Subpoena Will Impose Undue Financial Hardship on J Corder ML20150D1401988-03-21021 March 1988 Appeal of Director'S Decision on Southern Texas Project.* Requests That Commission Consider Appeal & Stay Licensing Decision Until Sufficient Evidence Acquired to Support Final Decision ML20148Q9531988-01-26026 January 1988 Petition of Gap.* Commission Should Delay Vote on Licensing of Facility Until Thorough Investigation of All Allegations Completed & Public Rept Issued.Exhibits Encl ML20236H3751987-10-29029 October 1987 NRC Staff Consent to Motion to Quash Subpoena Filed by E Stites.* Staff Concedes Possibility of Deficiencies in Svc of Subpoena to Stites & Therefore Does Not Oppose Motion to Quash.Certificate of Svc Encl ML20235T3891987-10-0808 October 1987 Motion to Quash Subpoena & Motion for Protective Order.* Subpoena Issued by Rd Martin on 870922 Should Be Quashed Due to Stites Not Properly Served,Witness Fees & Transportation Costs Not Provided & Issuance in Bad Faith ML20235T4171987-10-0808 October 1987 Memorandum in Support of Motion to Quash or in Alternative in Support of Motion for Protective Order.* Martin 870922 Subpoena of Stites Invalid & Improper.Decision to Subpoena at Late Date Form of Harassment.W/Certificate of Svc ML20216D1111987-06-25025 June 1987 Reply of Bp Garde to NRC Staff Opposition to Motion to Quash & De Facto Opposition to Petition Per 10CFR2.206.* NRC Has Not Established That Garde Assertions Not Sustainable.Certificate of Svc Encl ML20215D6471987-06-11011 June 1987 NRC Staff Answer Opposing Motion to Quash Subpoena Filed by Bp Garde,Esquire.* Gap Has Not Provided Sufficient Basis on Which Commission Could Conclude That attorney-client Privilege Protects Info Sought by Nrc.W/Certificate of Svc ML20214P3101987-05-29029 May 1987 Petition of Gap.* Requests That NRC Initiate Special Investigative Unit Complying W/Nrc Chapter Manual 0517, Excluding Region IV & V Stello from Participation,To Investigate Employee Allegations.Supporting Matl Encl ML20237G5981987-05-29029 May 1987 Motion to Reopen Record of Licensing Hearing to Determine Whether ASLB Conclusions Should Be Altered Due to Evidence of Undue Influence Exercised Over NRC Personnel by Util Mgt. Related Documentation Encl ML20214P2851987-05-29029 May 1987 Motion & Memo to Quash Subpoena.* Bp Garde Motion That Commission Quash V Stello 870520 Subpoena ML20203E1851986-07-22022 July 1986 Motion for Leave to File Supplemental Affidavit of Jn Wilson Re Design of Nonconforming Structures to Withstand Hurricanes & Tornados in Order to Correct Erroneous Statements Made in 860714 Affidavit.Related Correspondence ML20207E1131986-07-17017 July 1986 Statement of Views on Questions Re Design of Nonconforming Structures to Withstand Hurricanes & Tornadoes.W/Certificate of Svc.Related Correspondence ML20210E2071986-03-21021 March 1986 Motion to Compel Production of Documents Re Alleged Illegal Drug Use in Response to Applicant 860306 Response to Second Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20154Q1391986-03-19019 March 1986 Response Opposing Citizens Concerned About Nuclear Power, Inc 860228 Motion to Reopen Phase II Record:V & for Board Ordered Production of Documents.Motion Not Timely Filed. Certificate of Svc Encl ML20154Q3341986-03-19019 March 1986 Response Supporting Applicant Motion for Leave to Reply to Portions of Citizens Concerned About Nuclear Power,Inc Partial Response to Show Cause Order.Certificate of Svc Encl.Related Correspondence ML20138B0161986-03-17017 March 1986 Response to Citizens Concerned About Nuclear Power,Inc 860228 Motion to Compel Further Answers to Second Set of Interrogatories.Disclosure of Info Constitutes Invasion of Employee Privacy.Certificate of Svc Encl ML20138A8781986-03-14014 March 1986 Response Opposing Citizens Concerned About Nuclear Power,Inc 860221 Motion to Reopen Phase II Record.Affidavit of JW Briskin Encl ML20141N8461986-03-12012 March 1986 Motion for Summary Disposition of Issue F.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision.Affidavit of Je Geiger Encl ML20154B6111986-02-28028 February 1986 Response Opposing Portions of Concerned Citizen About Nuclear Power 860221 Partial Response to ASLB 860207 Show Cause Order.Further Arguments on Motion to Reopen Should Be Rejected.W/Certificate of Svc ML20154B4791986-02-28028 February 1986 Response Opposing Applicant 860218 Motion for Protective Order,Instructing Applicant Not to Answer 860204 Second Set of Interrogatories & Request for Production of Documents. W/Certificate of Svc.Related Correspondence ML20154B5781986-02-28028 February 1986 Motion for Leave to Reply to Portions of Concerned Citizen About Nuclear Power 860221 Partial Response to ASLB 860207 Show Cause Order.Proposed Reply Encl ML20154B8471986-02-28028 February 1986 Motion to Compel Applicant Response to Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20205K6151986-02-21021 February 1986 NRC Position in Response to ASLB 860207 Memorandum & Order Requesting Addl Info to Resolve Citizens Concerned About Nuclear Power,Inc Motion to Reopen Phase II Record:Iv. Certificate of Svc Encl ML20141N2131986-02-21021 February 1986 Motion to Reopen Phase II Record to Admit Encl Deposition of JW Briskin,For Order to Produce Documentation Re Quadrex Corp & to Schedule Hearings at Conclusion of Ordered Production of Documents.Certificate of Svc Encl ML20137W8841986-02-18018 February 1986 Motion for Protective Order to Direct Util to Respond to Only Interrogatories 12a,b & C in Citizens Concerned About Nuclear Power 860204 Second Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20151T7131986-02-0606 February 1986 Response Supporting Citizens Concerned About Nuclear Power, Inc 860117 Motion to Withdraw Contention Re Overpressurization of Westinghouse Reactors.Certificate of Svc Encl ML20151T6861986-02-0606 February 1986 Response Opposing Citizens Concerned About Nuclear Power,Inc 860117 Motion to Reopen Phase II Record for Discovery & to Suspend Further Activity in Phase III ML20151U6731986-02-0303 February 1986 Response to Citizens Concerned About Nuclear Power,Inc 860117 Motion to Reopen Phase II Record.Motion Supported to Include Addl Discovery & Hearings.Discovery Previously Limited by Board Contentions 9 & 10.W/Certificate of Svc ML20151T5841986-02-0303 February 1986 Response Opposing Citizens Concerned About Nuclear Power 860117 Motion to Reopen Phase II Record:Iv;For Discovery & to Suspend Further Phase III Activity.Util Withholding Quadrex Rept W/Intent to Deceive ASLB ML20198H2791986-01-29029 January 1986 Response Supporting Applicant 860109 Motion to Incorporate Corrections Into 851205 & 06 Transcripts.Certificate of Svc Encl ML20137J0971986-01-17017 January 1986 Motion to Reopen Phase II Record:Motion IV for Discovery & to Suspend Further Activity in Phase Iii.Encl EA Saltarelli Oral Deposition & Overview of Facility Engineering Should Be Entered Into Phase Ii.Related Correspondence ML20140B6191986-01-17017 January 1986 Motion for Withdrawal of Contention Re Overpressurization of Westinghouse Reactors.Certificate of Svc Encl ML20137A8731986-01-0909 January 1986 Motion to Incorporate Proposed Corrections to Transcript of 851205-06 Hearing ML20151T5291986-01-0303 January 1986 Response Supporting Citizens Concerned About Nuclear Power 860114 Motion to Withdraw Pending Contention on Overpressurization of Westinghouse Reactors.Certificate of Svc Encl ML20137L9501985-11-27027 November 1985 Motion to Sequester Witnesses to Be Called in Reopened Phase II Hearings on 851205 & 06 Re Issues of Credibility. Certificate of Svc Encl.Related Correspondence ML20210A4581985-11-13013 November 1985 Response Supporting Applicant 851014 Motion to Establish Schedule for Phase III of Proceeding.Certificate of Svc Encl ML20205G5251985-11-0808 November 1985 Response to Applicant 851014 Motion to Establish Schedule for Phase III Hearings.Proceeding Activities Re Phase III Should Be Suspended Until After Issuance of Partial Initial Decision Phase Ii.Certificate of Svc Encl ML20198B7991985-11-0505 November 1985 Motion Opposing Intervenor 851016 Motions to Reopen Phase II Record.Stds for Reopening Record Not Met.Certificate of Svc Encl ML20198B8431985-11-0404 November 1985 Motion to Strike Reckless Charges in 851029 Withdrawal Motion from Record.Intervenor Should Be Warned That Repetition of Behavior Will Not Be Tolerated.Certificate of Svc Encl ML20138N2431985-10-31031 October 1985 Response Opposing Citizens Concerned About Nuclear Power Motion to Reopen Phase II Record:Ii.Exhibits 2 & 4 Barren of Any Info on Quadrex Review or Results.W/Certificate of Svc ML20138N0291985-10-29029 October 1985 Motion to Withdraw 851016 Motion to Reopen Phase II Record & for Discovery.Certificate of Svc Encl ML20138H9981985-10-24024 October 1985 Response to Applicant 851004 Motion to Incorporate Transcript Corrections.Offers No Objection Except for Listed Proposed Changes.Certificate of Svc Encl ML20133J1521985-10-16016 October 1985 Motion to Reopen Phase II Record to Admit Four Encl Exhibits.Certificate of Svc Encl ML20133J3501985-10-16016 October 1985 Motion to Reopen Phase II Record & Extend Right to Discovery Set Forth in ASLB 850618 Memorandam & Order to All Parties. Certificate of Svc Encl 1992-06-29
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UNIED STATES OF AERICA lls 2 % -
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[.F . c- ,e i rj EEFORE THE ATOMIC SAFSTY AND LICENSING E0ARD Q g</ . -. M $
Q v Yv/ -lW IN TE MATIER OF ' l 2 *D HOUSTON LIGHTING AND PCNER DOCKET NCE 56-498 COMPANY, ET. AL. So-499 (SOUTH TEXAS PROJE0rS NOS. 112 i
MorION FOR CONTINUANCE NOW CCMES CITIZENS FOR EQUITABIE UTILITIES, INC. (CEU), INTERVENORS IN THE ABOVE CAPTIONED PROCEEDINGS, AND FIIES THIS ITS BRIEF IN SUPPORT (F A (30)
THIRTY DAY CONTINUANCE.
IN SUPPCRT OF THIS MOTION, CEU VOULD SHCV TE FOLLOWING:
CN APRIL 6,1979, DR. DONALD BEETH, AN EMPLOYES OF BROWN AND ROOT, THE CONIRACTOR OF RECORD FOR THE SOUTH TEXAS PROJECT, SERVED AS A PAh~s' LIST ON CHANNEL 8-HOUSTON VITH MRS. BUCHORN, DR. R. D. NEFF OF TEXAS A & M. AND MR. ANDREW SANSOM OF THE UNIVERSITY OF HOUSTON. AFTER THE TEIEVISION SHCW DR. BESTH MADE REFERENCE TO AN ORDER RULING ON INTERVENTION DATED APRIL 3,1979.
CEU HAD NOT RECEIVED THAT ORDER.
ON APRIL 10, 1979, MRS. BUCHCHN VAS INFORED BY A IEIEPHONE CALL THAT CCANP-SAN ANTONIO HAD RECEIVED THE CRDER BY MAIL ON 4-6-79. CEU HAD NOT.
ON APRIL 11, 1979, CCMMUNICATICI: FRCH ACEE-AUSTIN INFORMED MRS. BUCHORN OF 790eo70sts .
2233 069 1.
RECEIPT OF SUBJECT DOCUMENT BY MAIL ON b7-79. CEU STILL VAS VAITING.
ON APRIL 12, 1979, NINE DAYS AFTER THE DATE OF TE ORDER, MRS. BUCHORN CALIED MR. H. J. McGURREN, NRC COUNSEL. MR. McGURREN ASSURED MRS. BUCHORN THAT INDEED THERE HAD BEEN A DECISION AND THAT CEU HAD BEEN GRAFTED INTER-VENTION AND TWO CONIENTIONS. MRS. BUCHORN STAIED TO MR. McGURREN THAT SHE HAD NOF RECEIVED NOTIFICATION BY MAIL AND THAT IT VAS IMPOSSIBIE TO REPLY TO SOMETHING THAT HAD Nor BEEN SEEN. MR. McGURREN ASSUBED MRS. BUCHORN THAT A COPT OF THE ORDER VOULD BE PIACED IN THE MAIL THE FOLLOWING MORNING,bl3-79.
DURING THAT CONVERSATION MR. McGURREN ARRANGED TO ASSIST MRS. BUCHORN IN CURING DEFECTS IN PHRASE 0 LOGY OF CEU'S ETITION.
ON APRIL 18, 1979, MRS. BUCHCHN RECEIVED A IELEPHONE CALL FROM MR McGURREN SEEXING TO CHANGE THE APPOINTMENT FRm MAY 2,1979 TO MAY 9,1979. TE REASON - TE APPLICANT HAD FILED A NOTICE OF APEAL OF THIS ORDER THAT CEU STILL HAD NOT RECEIVED. WHEN MRS. BUCHORN INFCRMED HIM OF THIS FACT, COUNSEL THEN SUCCESTED THAT MRS. BUCHORN GO TO TE POST OFFICE AND REQUEST A TRACE OF TE MAIL. MRS. BUCHORN ASKED FOR A TRACE TO BE INITIATED FOR TE ITEMS THAT SE HAD BEEN ASSURED HAD BEEN MAIIRD, FIRST CI b3-79 AND AGAIN ON bl3-79.
TE POSTMISTRESS STATED THAT IT WOULD BE WISE FOR A TRACE AISO TO BE INITIATED AT THE POINT OF ORIGIN AS TERE WAS UNCERTAINTT AS TO THE SIZE, NUMBER OF PACES, ETC. MRS. RICHORN IMMEDIATELT DROVE TE EIEVEN MIIES BACK TO ER HOME AND PIACED A CALL TO THE OFFICE OF MR. CHARIES BECHHGFER IN VASHINGTON. MR.
BECHHGFER'S SECRETART INFORMED MRS. BUCHORN THAT ALL DOCUMENTS VERE SENT TO T E DOCIETING AND SERVICE SECTION FOR MAILING. MRS. BUCHORN TEN CAT.TRD DOCETING AND SERY1CE IN VASHINGTON AND TALKED TO MR. CHASE suntss, EXPIAINING w
- o A =
2233 070 2.
TE PROBEM. MR. SEPENS STATED THAT HE WOULD INVESTIGNIS AND CALL MRS.
BUCHORN LATER. SHORTLY TEREAFER MR. STEPHENS CALED MRS. BUCHORN. AND SAID THAT IT WAS TEIR FAULT THAT THE ORDER HAD NCfr BEEN MAILED. haS. BUCHORN TEN ASED HOW MANY ITEMS HAD NOT BEEN MAIED AND MR. SEPHENS SAID THFRE WERE POSSIBLY OTERS AISO. MRS. BU/: HORN T.EN SAID THAT SE V00LD PREPARE A M0rION FOR A CONTINUANCE AND MR. STEPHENS STATED THAT TE REQUEST WAS PROER UNDER TE CIRCUMSTANCES AND THAT E WOULD CALL MR. BEC20EFER AND ADVISE HIM OF TE PROBLEM.
ON APRIL 19, 1979, MRS BUCHORN RECEIVED IN Th2 MAIL A IEITER CONTAINING A NOTICE OF APEAL BY TE APPLICANT OF AN ORDER THAT SE STILL HAD N0r RECEIVED.
ON APRIL 20, 1979, THE ORDER ARRIVED AND MRS. BUCHORN AGAIN CALED WASHINGTON, THIS TIE TO INFORM MR STEPENS THAT TE ORDER, SEVENTEEN DAYS LATE, HAD ARRIVED.
ON APRIL 21, 1979, MRS. BUCHORN RECEIVED TE "APPUCAFIS MTW ON APEAL FRCH PREEARING CONEENCE ORDER RULING UPON INTERVENTION ETITIONS".
CEU FINDS IT ENTIRELY IMPOSSIBLE TO ACCOMPUSH THAT WHICH WOULD BE REQUIRED IN THE ORDER IN TE REMAINING TIME FRAME. IT IS TEREFORE TE POSITION OF CEU THAT A 30-DAY CONTINUANCE E GRAFIED FOR THE REASONS SET FORTH ABOVE.
VEREFORE, PREMISES CONSIDERED, CSU 1*?JLD PEAY THAT THE ATOMIC SAFETY AND U CENSING BOARD GRAFI THIS M0rION.
RESECTFULLY SUBMITTE
@ D M' '
- 481 v d i O {} M g j' [ } y MRS. PEGGY EUCHORN, EIEC. DIR.
CITIZENS FOR EQUITABE UTI U TIES, INC.
ROUTE 1 BOX 432 BRAZCRIA, TEXAS, 77422 2233 071 3.
UNITED STAIES OF AMERICA NUCLEAS REGUIATORY C mMISSION BEFOE TE ATOMIC SAFETY AND LICENSING BOARD h
IN TE MATIER 07 HCUSTON LIGHTING AND F0WER DOCKET NOS. 5 M 98 COMPANT, ET AL. h S M 99 (SourH TEXAS PROJECT, UNITS 1 & 2) o i
CERTIFICAM OF SERVICE 4
I EREBT CERTIFY THAT COPIES OF MOTION FOR CONTINUANCE BY CITIZENS FOR EQUITABIE UTILITIES, INC. WERE SERVED ON TE FOLLGVING BT DEPOSIT IN TE UNITED STATES MAIL THIS 22_nd DAT OF APRIL, 1979:
CHARLES ECHMCEFER, ESQ., CHAIRM ATWIC SAFETT AND LICENSING BOARD U. S. NUCIEAR REGUIAT0itY COMMISSION WASHINGTON, D. C. 2e555 DR. JAMES C. LAMB, III 313 WOODHAVEN ROAD CHAPEL HILL, NORTH CAROLINA 27514 DR. EMMETH A. LUE3XE ATmIC SAFETT AND LICENSING BOARD U. S. NUCIEAR REGUIATORI CCHMISSION VASHINGTON, D. C. 2e555 ENRY J. McGURREN, ESQUIRE EARING AITORNET OFFICE OF TE EXECUTIVE IEGAL DIRECTOR U. S. NUCIEAR REGULATORY CCHMISION VASHINGTON, D. C. 20555 RICHARD V, LOERRE, ESQUIRE ASSISTANT ATTORNET GENERAL, STATE OF TEXAS P. O. BOX 12548 CAPITOL STATION AUSTIN, TEXAS 78711 2233 072 bl [kN[4[
HONORABLE EURT O'CONELL COUNTT JUDCE, MATAGORDA COUNTY MATAGORDA COUNTY COURT HOUSE BAT CITY, TEXAS 77414 B. GORDON GOOCH, ESQUIE 1741 ENNSTLVANIA AVENUE, N. V.
VASHINGTON, D. C. 24646 MR. IANNY SINKIN CITIZENS CONCERED ASCUT NUCLEAR POWER 838 E. MAGNOLIA SAN ANTONIO, TEIAS 78212 MR. DAVID MARIE 39 M VAREHOUSE ROV SUITE C AUSTIN, TEXAS 7876 AUSTIN CITIZENS FOR ECONOMICAL EERGY HR. ROGER DUNCAN 961 VEST 241h STEET AUSTIN, TEXAS 78705 ATOMIC SAFETT AND LICENSING APEAL BOARD U. S. NUCIEAR REGULATORY CClotISSION VASHINGTON, D. C. 28555 VR CHASE R. STEPENS DOCKETING AND SZHVICE SECTION .
OFFICE OF TE SECETARY OF THE COMMISSION U. S. NUCIEAR REGULATORY CCEMISSION VASHINGTON, D. C. 26555 MELIERT SCRVARZ, JR. ESQ.
3AER AND BOITS CHE SELL PLAZA HOUSTON , TEXAS 77002 JACK R. NEYMAN, ES9.
LOVENSTEIN, NLM, REIS & AXEIRAD le25 CCHECTICUTT AVENUE, N.V.
VASHINGTON, D. C. 20036 ATCMIC SAFETY AND LICENSING APIEAL ?ANEL U. S. NUCIEAR REGULATORT CCRMISSION VASHINGTON, D. C. 29555
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