ML19323F976
| ML19323F976 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 05/01/1980 |
| From: | Biddle C, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005300047 | |
| Download: ML19323F976 (23) | |
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UNITED STATES OF AMERICA LE yay 51980 > -5 NUCLEAR REGULATORY COMMISSION CMCO Clthe Secreb!7 C ggcksi!r.g & SCWICS CWCh 0 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
% A cn In the Matter of S S
HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 1
S (Allens Creek Nuclear S l
Generating Station, Unit S No. 1)
MOTION TO CONFIRM AGREEMENTS ON CONSOLIDATION AND TO CONSOLIDATE CERTAIN CONTENTIONS I.
In its order of March 10, 1980, this Board directed the intervenors in this proceeding with consolidated contentions )
1 to identify which one of the intervenors would conduct discovery, i
present evidence, cross-examine, and submit briefs, proposed findings of fact, conclusions of law and argument (hereinafter referred to as " lead party"). The Board also directed that if there were substantially similar contentions inadvertently left unconsolidated, the involved parties should agree upon consolidation and identify which one of the parties would act for the consolidated group.
- In order to facilitate this process, the Applicant sent letters to each of the involved parties indicating either that certain contentions were consolidated by the Board's order and requesting a designation of the lead party or noting substantially similar contentions which have not l
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been formally consolidated and proposing such consolidation along with a combined restatement of the consolidated con-tentions.
Most of the involved parties responded promptly either by letter (attached) or by telephone. The following agreements as to the consolidation of contentions and the designation of a lead party in each instance have been reached.
Underscoring in the list below indicates the lead party which will conduct all activities as described in the Board's order of March 10.
- 1. Hinderstein No. 5 and Bishop No. 23 (c) .
- 2. Bishop No. 1 and Lemmer No. 1.
- 3. Baker No. 1, Cumings No. 1 and TexPirg Additional Contention No. 32.
- 4. Doggett No. 4 and Perrenod No. 1.
- 5. TexPirg No. 1, Bishop No. 23 (a) , Conn No. 2, Cumings No. 4, Doggett No. 2, Johnston No. 5-2/b-2 and Lemmer No. 2.
- 6. TexPirg No. 5 and Cumings No. 6(b).
- 7. TexPirg Additional Contention No. 31 and Doggett No. 3.
- 8. TexPirg No. 2, Griffith No. 4 and McCorkle No.
2.
- 9. Doherty No. 8 and TexPirg No. 8.
- 10. Rentfro No. 2 and Marrack No. 2 (.,) .
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- 11. Doherty No. 17 and TexPirg No. 51.-1/
- 12. TexPirg No. 7, Doggett Nc.1(a) and Cumings No. 6 (c) .
Applicants and the other involved parties also agreed that the designation of TexPirg,as lead participant on contentions previously admitted, and for which TexPirg's discovery period had lapsed, would not affect the discovery rights of the newly admitted parties. In this regard, TexPirg will act as agent for the new parties and will exercise their discovery rights. It is further agreed among the parties that this limited reopening of discovery on previously admitted contentions will not be used by TexPirg to expand its own discovery.
II.
After numerous attempts, Applicant was unable to prompt a designation of a lead party for two contentions previously consolidated by the Board. Therefore, Applicant requests that the Board order the involved parties to appoint I a lead party for the following consolidated contentions within ten (10) days of its order:
- 1. Bishop No. 6 and TexPirg Additional Contention No. 23- ,
- 2. Bishop No. 13 and Doggett No. 1(b).
1/ A proposed combined restatement of the consolidated contentions is provided in Section IV of this motion. ;
l 2/ See footnote 1, supra. l 3/ See footnote 1, supra.
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III.
After similar efforts, Applicant was also unable to reach an agreement with the involved parties concerning the consolidation of contentions which are substantially
'i similar but were left unconsolidated in the Board's prior
! orders. In an effort to facilitate the consolidation process, and in light of the Board's instructions directing l that the parties agree upon succinctly worded contentions, i Applicant also proposed to the parties involved combined restatements of these nearly identical contentions. None of the parties responded. Therefore, Applicant requests that the Board order consolidation on the following contentions, adopt the stated language as the consolidated contention and require a designation of lead party within ten (10) days of its order;
- 1. TexPirg No. 6, McCorkle No. 10 and Bishop No.
48.
"The maximum credible accident has not been considered because the present safety and environmental analyses do not consider the effects of a large airplane, such as a Boeing 747, crashing into the containment vessel. Applicant's estimate as to the probability of such a crash is understated because (1) large plane traffic has increased at least 30 percent in the last three years, and will be several hundred percent higher before the plant is closed in about 40 years; and (2) new airports capable of handling such 4/ Applicant has received a letter from Mr. Bishop (attached) which designates TexPirg as its representative for litigating this consolidated contention. Conversations with TexPirg's counsel, Mr. Scott, indicate that TexPirg has not " consented" to this arrangement.
large airplanes have been proposed to be built in the Fort Bend County area much closer than present airports. Accordingly, the plant (1) should be moved much further away from population centers or
- (2) the plant containment should be strengthened to withstand the crash of the largest plane that is allowed to fly in the Houston area. This can be done by doubling the thickness of the containment vessel or by burying the plant."
- 2. Doherty No. 11 and Framson No. 1.
" Applicant has not provided adequate design characteristics and operacing safeguards to protect the integrity of 4 stored spent fuel during unattended ,
operation of the spent fuel pool. In addition, the Final Environment Statement is inadequate in failing to consider the consequences of a spent fuel pool design basis accident."
- 3. TexPirg No. 11 and Doherty No. 31.
" Applicant has not adequately assessed the effects of flow-induced vibration on jet pumps, spargers, fuel pins, fuel rods and core instrumentation, particularly, the local power range monitors (LPRM).
Degradation of the LPRMs as the result of flow-induced vibration will impact the )
reliability of reactivity monitoring and control in the fuel rods, possibly leading to administrative derating of the reactor. Current plans for 33 LFRMs are insufficient to prevent eithe. administrative derating or accident hazards sach as power excursions."
- 4. Bishop No. 13 and Doggett No. 1(b):
"The FSFES S 9.1.2.3 is deficient in that (a) the environmental costs of coal were overestimated because these costs were based on a nationwide rather than on a source specific analysis, i.e., on an ,
analysis of the Powder River Basin as the .I source of coal, using a coal slurry I pipeline for delivery, (b) the economic j I
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conto of constructing and fueling nuclear plants are escalating more rapidly than costs for constructing and fueling coal
' plants; and (c) the Staff's coal versus nuclear analysis has not accurately taken into account the rate of escalation of the price of uranium."
IV.
In light of the Board's instructions in its May 10th I
order directing that the parties agree ugan succinctly worded l 1
contentions, Applicant proposed to the involved parties combined restatements of contentions already consolidated in previous I l
orders by the Board or by mutual agreement.-5/ As noted in Section I of this motion, the parties involved have agreed to the designation of a lead party; however, they have made no response to the proposed restatement of the combined contentions.
None of the parties involved chose to respond to this proposal.
Therefore, Applicant requests that the Board adopt the following language as the consolidated statement for the contentions i
noted:
Doherty Contention 17 and TexPirg Additional Contention No. 51:
"Intervenor contends pressure from blowdown following an Anticipated Transient Without Scram (ATWS) a power excursion accident (PEA)', Loss of Coolant Accident (LOCA) or Powe'r Coolant Mismatch Accident (PCMA) combined with a single or several l struck relief valves may hit the suppression l pool with sufficient force to permit escape of radioactive gases by causing cracks in the containment building wall 5/ To the best of Applicant's knowledge, in all other instances where contentions were consolidated, the Board's order or the informal arrangement reached set the wording of the combined contentions. A combined statement of the remaining consolidated contentions is an important prerequisite to discovery and the further refinement of contention wording.
cnd endnngar Intervanor's health cnd genetic safety interests. There has been considerable unreliability in pressure relief systems in BWRs, and the reduction from 22 to 19 relief valves increases the danger from' failure of any single relief valve or more than one relief valve.
Applicant should be required to recearch all data on such valves, and:
- a. commit to the use of one type with best regard of performance during blowdown conditions; or
- b. use a variety of manufacturer's products to prevent common mode :
failure."
Cumings Contention No. 6 (c) , Doggett Contention ,
No. 1(a) and TexPirg Contention No. 7:
"There has not been a dispositive assessment of *he energy demand reduction potential thc'. might derive from conservation measures available to applicant, because:
- a. direct capital investment by the Applicant ror conservation re.rofitting in the service ,
l ate; has not been considered; i b. inadequate attention has been l given to the likelihood that '
major industrial users in the Houston area will be producing their own energy in the near future;
- c. the rate structure of the Applicant does not provide an incenti"e for energy conserva-tion; and
- d. neither the Applicant nor the Staff has considered the increased use of ' passive solar' techniques."
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V.
i Applicant has now worked for five weeks in its attempt i to carry out the Board's instructions on the consolidation and
rewording of contentions and the designation of lead parties.
Applicant appreciates the cooperation of other parties in accomplishing what has been done to date; however, for reasons that are not apparent to Applicant, it appears that the informal attempts to resolve these issues have now reached an impasse which can only be broken by having the Board interpose. As the Board can appreciate, a prompt resolution of these simple procedural matters is necessary to an orderly conclusion of discovery. Accordingly, Applicant I
requests that the Board issue the attached proposed order.
Respectfully submitted, OF COUNSEL:
C.
J.
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Gregory Copeland 9 C. Thomas Biddle, Jr. ,
BAKER & BOTTS Darrell Hancock l 3000 One Shell Plaza Charles G. Thrash, Jr.
Houston, Texas 77002 3000 One Shell Plaza Houston, Texas 77002 1 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman l AXELRAD & TOLL Robert H. Culp 1025 Connecticut Avenue, N.W. 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 Washington, D.C.
ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & PONER COMPANY
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Sheldon J. Wolfe, Esq., Chairman Dr. E. Leonard Cheatum, Member Gustave A. Linenberger, Jr., Member l
l In the Matter of S i S
COUSTON LIGHTING & POWER S COMPANY S , Docket No. 50-466 S
(Allens Creek Nuclear S Generating Station, Unit S No. 1) l l
ORDER (May , 1980) ,
1 On May 1, 1980, Applicant filed a Motion To Confirm Agreements On Consolidation And To Consolidate Certain Contentions. In that motion, Applicant made a reference to the fact that our Order of March 10, 1980, directed that parties consolidated on substantially similar contentions suould agree and advise the Board which one shall conduct discovery, present evidence, cross-examine, and submit briefs, proposed findings of fact, conclusions of law and argument upon said contentions. That Order also directed that if there are other substantially similar contentions which per chance were not consolidated by the Board, the involved parties should
agree upon consolidation and advise which one will conduct the various activities listed. Applicant now reports that agreement on consolidation and the selection of lead parties representing consolidated groups in the majority of instances is complete. However, Applicant points out that the parties were unable to reach a total agreement on all matters relating to consolidation of contentions. Applicant maintains that reaching a satisfactory resolution of these issues is necessary for the expeditious completion of discovery. Therefore, Applicant requested the Board to order the involved parties to appoint a lead party for consolidated contentions and to l
consolidate substantially similar contentions as restated in Applicant's motion.
l The instant motion is granted. Within ten (10) days !
of this Order, the involved parties will appoint a lead party which shall conduct discovery, present evidence, cross-examine, and submit briefs, propose findings of fact, conclusions of law and argument upon the following contentions:
- 1. Bishop No. 6 and TexPirg Additional Contention l
No. 23.
- 2. Bishop No. 13 and Doggett No. 1(b).
The following contentions are consolidated and the stated language is adopted as the consolidated contention.
Within ten (10) days of this Order, the involved parties will l
designate a lead party to conduct the various litigation activities:
- 1. TexPirg No. 6, McCorkle No. 10 and Bishop No.
48.
"The maximum credible accident has not been considered because the present safety and environmental analyses do not consider the effects of a large airplane, such as a Boeing 747, crashing into the containment vessel. Applicant's estimate as to the probability of such a crash is understated because (1) large plane traffic has increased at least 30 percent in the last three years, and will be several hundred percent higher before the plant is closed in about 40 years; and (2) new airports capable of handling such large airplanes have been proposed to be built in the Fort Bend County area much i
closer than present airports. Accordingly, the plant (1) should be moved much
- further away from population centers or l
(2) the plant containment should be strengthened to withstand the crash of the largest plane that is allowed to fly in the Houston area. This can be done by doubling the thickness of the containment r
vessel or by burying the plant."
- 2. Doherty No. 11 and Framson No. 1. l
" Applicant has not provided adequate design characteristics and operating safeguards to protect the integrity of stored spent fuel during unattended operation of the spent fuel pool. In addition, the Final Environment Statement is inadequate in failing to consider the consequences of a spent fuel pool design basis accident."
- 3. TexPirg No. 11 and Doherty No.-31.
" Applicant has not adequately assessed the effects of flow-induced vibration on
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jet. pumps, spargers, fuel pins, fuel rods and core instrumentation, particularly, the local power range monitors (LPRM).
Degradation of the LPRMs.as the result of flow-induced vibration will impact the reliability of reactivity nonitoring and control in the fuel rods, possibly ~
leading to administrative derating of the reactor. Current plans for 33 LPRMs are insufficient to prevent either administrative derating or accident hazards such as power excursions."
- 4. Bishop No. 13 and Doggett No. 1(b) :
"The FSFES S 9.1.2.3 is deficient in that (a) the environmental costs of coal were overestimated because these costs were based on a nationwide rather than on a source specific analysis, i.e., on an analysis of the Powder River Basin as the source of coal, using a coal slurry pipeline for delivery, (b) the economic costs of constructing and fueling nuclear plants are escalating more rapidly than costs for constructing and fueling coal l plants; and (c) the Staff's coal versus nuclear analysis has not accurately taken I into account the rate of escalation of I the price of uranium."
The following language is adopted as the consolidated statement or the combined contentions noted:
Doherty Contention 17 and TexPirg Additional Contention No. 51:
"Intervenor contends pressure from blowdown following an Anticipated Transient Without Scram (ATWS) a power excursion 1/ -The parties involved in these two contentions agreed to con-solidation of these contentions but failed to respond to Applicant's suggested amalgamation of their contentions. We find that the Applicant's suggested combination faithfully restates each party's contention.
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i accident (PEA), Loss of Coolant Accident (LOCA) or Power Coolant Mismatch Accident (PCMA) combined with a single or several struck relief valves may hit the suppression pool with sufficient force to permit escape of radioactive gases by causing cracks in the containment building wall and endanger Intervenor's health and genetic safety interests. There has been considerable unreliability in pressure relief systems in BWRs, and the reduction from 22 to 19 relief valves increases the danger from failure of any single relief valve or more than one relief valve.
Applicant should be required to research all data on such valves, and:
- a. commit to the use of one type with best regard of performance during blowdown conditions; or ,
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- b. use a variety of manufacturer's l products to prevent common mode failure." 1 Cumings Contention No. 6 (c) , Doggett Contention No.
1(a) and TexPirg Contention No. 7:
"There has not been a dispositive assessment of the energy demand reduction potential that might derive from conservation measures available to applicant, because: *
- a. direct capital investment by the Applicant for conservation retrofitting in the service area has not been considered; b, inadequate attention has been given to the likelihood that major industrial users in the Houston area will be producing their own energy in the near future;
- c. the rate structure of the Applicant does not provide an incentive for energy conserva-tion; and
- d. neither the Applicant nor the Staff has considered the increased use of ' passive solar' techniques."
THE ATOMIC SAFETY AND LICENSING BO* TtD 1
Sheldon J. Wolfe, Esq.
Chairman i
I Dated at Bethesda, Maryland, this day of May, 1980. l l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S
HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 S
(Allens Creek Nuclear S Generating Station, Unit S ,
No. 1)
I CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Motion to Confirm Agreements on Consolidation and to Consoli-data Certain Contentions in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 1st day of May, 1980.
Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P.O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 -
Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Mr. Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regtlatory Washington, D. C. 20006 Commission Washington, D. C. 20555
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Steve Sohinki, Esq. Carro Hinderstein Staff Counsel 609 Fannin, Suite 521 U.S. Nuclear Regulatory Commission Houston, Texas 77002 Washington, D. C. 20555 D. Marrack Mr. Bryan L. Baker 420 Mulberry Lane 1118 Montrose Bellaire, Texas 77401 Houston, Texas 77019 Mr. J. Morgan Bishop Stephen A. Doggett, Esq. '11418 Oak Spring P. O. Box 592 Houston, Texas 77043 Rosenberg, Texas 77471 Mr. John F. Doherty Robert S. Framson 4327 Alconbury Madeline B:ss Framson Houston, Texas 77021 4822 Waynesboro Houston, Texas 77035 Ms. Brenda McCorkle 6140 Darnell Mr. W. Matthew Perrenod Houston, Texas 77074 4070 Merrick Houston, Texas 77025 Mr. Wayne E. Rentfro P. O. Box 1335 Mr. James M. Scott Rosenberg, Texas 77471 13935 Ivy Mount Sugar Land, Texas 77478 Mr. F. H. Potthoff 7200 Shady Villa, No. 110 Houston, Texas 77080
- U C. Thomas Biddle, Jr. /
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.uc s ++ s o j OHIO PUBLIC INTEREST RESEARCH GROUP 1
1 I> h STATE OFFICE 65 S. 4th ST. COLUMBUS, OHIO 43215 I6141461-0136
.I OTHER OFFICES: OBERLIN COLLEGE, WITTENBERG UNIVERSITY, UNIVERSITY OF DAYTON, WILMINGTON COLLEGE, CAPITAL UNIVERSITY !
I April. 1, 1980 J. Gregory Copeland Baker & Botts One Shell Plaza Houston, TX 77002
Dear Sir:
This is to inform you that Mr. Stephen A. Doggett will be the pri e f party in conducting discovery, presenting of evidence, cross-examination and submission of briefs, proposed findings of fa::t, and conclusions of law and argument vi'th respect to our consolidated contention from the ACUS proceeding, ?EC Cocket No. 50-466.
Sincerely, l
W. Matthew Perrenod WMP/ja l
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J. Gregory Copeland --
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Attorney at Law Baker and Botts One Shell Plaza M[7/f////-Jfr/ ;
Houston, Texas 77002 April 15, 1980 Re: Houston Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1); Docket No. 50-466
Dear Mr. Copeland:
I have spoken with J. Morgan Bishop about consolidating my contention No. 5 and Mr. Bishops 's contention No. 23(c) . I will conduct discovery, present evidence, cross-examine, submit briefs, propose findings of fact and conclusions of law, and present argument on the consolidated contention.
Mr. J. Morgan Bishop requests that he be sent a copy of any letters, interrogatories, or any other written communication regarding the above consolidated contention.
Sincerely, D
Carro Hinderstein cc: Mr. J. Morgan Bishop 11418 Oak Spring Houston, Texas 77043 Docketing and Service Section Office of the Secretary of the Commission Nuclear Regulatory Commission Washington, D.C. 20555 ch:ga l A
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April 6, 1980 Sheldon J. Wolfe, Esq. Dr. E. Leonard Cheatum Chairperson Route 3 Sox 350 A Atomic Safety & Licensing Board Watkinsville, Ge. 50677 U. S. ITuclear Regulatory Comm.
Washington D. C. 20555 Gustave 1. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Comm.
Washington D. C. 20555
Dear Mr. Copeland,
In regard to your, Registered Letter of 3/25/80 (enclosed to Staff and the Board)concerning my Contention #8 and Tex?IRG Contention p8, I have been authorized by TexPIRG to indicate i to you that I will be the person perform the several activities l
listed., ,
This response, is not to be construed that 10 days is 1 I
a reasonable amount of time for myself to decide on matters of all contention consolidationr in the proceedings, however. ,
1 I note you indicate conducting discovery as one of the activities in which I may involve myself for preparation for the hearings. I do not believe I have the right to con-duct such discovery on Contention #8, nor do I believe Applicant hap such rishts at this time. Therefore, I am giving notice that I will resist dicovery on this Contention from Applicant, should that be forthcoming. ,
Sincerely, ohn F. Doherty Party-Intervenor in the Allens _
jfd Creek CP proceedings (50-466) xc- All parties.
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April 11, 1980 Re: Houston Lighting & Power Company Allens Creek Nuclear GS Dockett No. 50-466 To whom it may concern:
The unders16ned below designate TexPirs as our representative in the consolidating orders of the Atomic Safety and Licensin6 Board.
These orders involve Bishop Contention 23(a), Conn Contention 2, Johnston Contention 5-2/6-2 and Lemmer Contention 2.
Please address inquires to TexPirs. Please keep us informed.
Yours truly, 0 Y~,/ &&MjW z-f
. Morgun Bish @ Mar 5are.t Bishop l\ -n. Jk ?. L- U Gv's m '{. v' Mrs. Leotis Johnstop Mrs. Rosenfary N. Lemmer 0*L C 4(- %V Carolina Conn I
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11418 Oak Sprin6 Houston, Texas 77053 April 10, 1980 Re: Houston Power and Lightin6 Company _
Allens Creek NGS Docket No. 50-466 J. and Mar 6aret Bishop wish to desis.nate Ms. Carro Hinderstein as our representative in the consolidating of our mutual contentions !
(Bishop 23c and Hinderstein 5). j i
Please direct inquiries to Ms. Hinderstein. Please keep us informed of any develop ments. ;
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Yours truly,
'reay & &
J. Morgan Bishop Mar 6aret Bishop 1
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11418 Oak Spring l Houston, Texas 77043 April 10, 1980 ]
1 Re: Houston L15 htin 6 & Power Company Allens Creek Nuclear Generatin5 Station Unit 1, Docket No. 50-466 To Whom It May Concern:
It is a6 reed between Mrs. Rosemary Lemmer and J. and Margaret Bishop that the Bishop's will represent Mrs. Lemmer in the consolidating of Contention 1 of the.above.
Please direct inquires to the Bishop's regardin5 Contention 1.
Yours truly,
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Rosemary Lemmer J. Mor6an Bishop Mar 6aret Bishop l
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i April 11, 1980 Houston L16htin6 & Power Allens Creek NGS Dockett 50-466 We the undersi6ned designate TexPir6 to represent us in our Contention 18 and TexPir6's Contention 6.
Please direct inquires to TexPir6 Please keep us informed.
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Yours truly, l l
A g.M6r6anBishoyf Mar 6aret Bishop .
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