ML19350C747

Answers to Third Set of Interrogatories from Util.Applicants Already Have Documents Requested.Intervenors Removed Nothing from Swayze Atty Files.Certificate of Svc Encl.Related Correspondence

ML19350C747
Person / Time
Site:	South Texas
Issue date:	03/16/1981
From:	Sinkin L Citizens Concerned About Nuclear Power, INC.
To:	HOUSTON LIGHTING & POWER CO.
References
ISSUANCES-OL, NUDOCS 8104060656
Download: ML19350C747 (2)

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In the Matter of 6 Q 6

HOUSTON LIGHTING AND ,5 Docket Nos. STN 50-498 OL POWER COMPAhT, ET AL. 5 STN 50-499 OL 9

(South Texas Project. 5 Units 1 and 2) 5 ANSWERS OF CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC.

TO THIRD SET OF INTERROGATORIES FROM HOUSTON LIGHTING AND POWER COMPAhT, ET AL., APPLICANTS

1) The documents requested and the " bundle of documents" are believed to be the same documents. Applicants already have copies or the originals of all these documents.

2) CCANP removed no documents from the files kept by Mr.

Swayze's attorneys in his litigation with Brown and Root, Inc., Cause No. 23,714 in the district court of Matagorda County. Texas.

3) To the best of my knowledge, there are no STP construction records in CCANP's possession other than .those specified in the interrogatory.

4) CCANP objects to Interrogatory 4 as unduly burdensome, vague, and irrelevant to these proceedings. If the Applicants are looking for their missing paperwork, I can state that I know of no individual who has any.

W 4/2tu State of Texas 5 County of Travis5 BEFORE ME, the undersigned authority, on this day personally appeared Lanny Alan Sinkin, who on his oath states that he has read the above and foregoing and knows the same ph

'to be true and correct.

5L2h L ny 81nkan, CCANP sd UBSCRIBED AND SFORN to before me by LANhT SITeCIN on I4 day of March, 1981.

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'LkIM }L[&MI h.hy, N tary Public n and 8104060/s G for Travis Cou ty, Texas MyCommissionexpires:h-2/cN .

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Certificata of Service l I' hereby certify that the foregoing document has been served on the following individuals and entities by hand (*) or by deposit in the U.S'. Mail, first class, postage prepaid on this _f@l day of March, 1981.

Lannyg61nkin Charles Bechhoefer,' Esquire

• Mr. Jack Newman

• Chairman Lowenstein, Newman, Reis, Atomic Safety and Licensing Board Axelrad, & Toll U.S. Nuclear Regulatory Commission 1025 Connecticut Avenue, NW

. Washington, D.C. 20555 Washington, D.C. 20036 Dr. James C. Lamb

• Docketing and Service Sect. ion (7) 313 Woodhaven Road Office of the Secretary Chapel Hill, North Carolina 27514- U '. S . Nuclear Regulatory Ccamissio:

Washington, D.C. 20555 Mr. Ernest E. Hill

• Lawrence Livermore Laboratory Atomic Safety and Licensing University of California Board Panel .

P.O. Box 809, L-123 U.S. Nuclear Regulatory Commissiot Livermore, Ca. 94550 Washington, D.C. 20555 Edwin J. Reis

• Atomic Safety and Licensing Office of the Executive Appeal Panel (5)

Legal Director U.S. Nuclear Regulatory Commissio:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 ,

Brian E. Berwick

• Assistant Attorney General for the State of Texas Mrs. Peggy Buchorn Route 1, Box 1684 Brazoria, Texas .

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