ML20087N685

Motion for Addl Discovery of 90 Days Re Performance of Qa/Qc Program.Certificate of Svc Encl.Related Correspondence

ML20087N685
Person / Time
Site:	South Texas
Issue date:	03/29/1984
From:	Sinkin L Citizens Concerned About Nuclear Power, INC.
To:	Atomic Safety and Licensing Board Panel
References
OL, NUDOCS 8404040183
Download: ML20087N685 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 84 APR -2 All .g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g.Fi ., - af u 5, Es $ p *:

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In the Matter of (

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HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL POWER COMPANY, ET AL. ) 50-499 OL

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(South Texas Project, ) ,

Units.1 and 2) ( g*

CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP) dQI1QN EQB ODQlliQNOL Di@ggyESY On March 14, 1984, the Atomic Safety and Licensing Board in this proceeding issued its Partial Ini ti al Decision. ASLBP No.

79-421-07 OL. As part of that decision, the Board directed the NRC Staff "(and the Applicants and other parties if ' they wish)"

to provide a report on " safety related construction activities (including implementation of the OA/DC program) following the assumption of duties by Bechtel and Ebasco." id. at 6; See also

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1, d . at 56-57, 286.

'In essence, the Board has extended into the second phase of the operating license proceeding the' inquiry posed by Issue B, i

l 1.e. . whether the remedial actions taken by HLttP provide a sufficient basis for concluding that HL&P has the necessary character and competence to receive an operating license for a

= nuclear power plant.

The Partial Ini ti al Decision was the first notice CCANP had that the record on Issue B would be extended during Phase II.

! This extension of the issue is in part recognition of arauments presented by Citizens Concerned About Huclear Power, Inc. (CCANP) in its Findings of Fact and Conclusions of Law for B404040183 840329 gDR ADOCK 05000 g ]QK

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' Phase I of this proceeding. Id. at 55-56.

In order to be adequately prepared to participate in the litigation of this issue, CCANP requires further discovery on the performance of HL&P, Bechtel, and Ebasco since the transition from Brown and Root to Bechtel and Ebasco.

For the above and foregoing reasons, CCANP moves the Board to provide ninety (90) days of discovery to CCANP regarding this

, .r e

. performance.

Respectfully submitted,

/

Lanny Sinkin

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Representative for Intervenor Citizens Concerned About Nuclear Power, Inc.

114 W. 7th, Suite 220 Austin, Texas 78701

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[ (512) 478-7197

. . Dated:; March 29, 1984 l .l

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3, UNITED STATES OF AMERICA CX HE TE:, NUCLEAR REGULATORY GOMMISSION ' 73 C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

                                                                                          'g4 APR ~2 AU l07 In.the Matter of                        (                             Uff!n ;.f -
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HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL 3AANCH

           .         POWER COMPANY, ET AL.                 )                   50-499 OL (South Texas Project,                   (

Units 1 and 2) ( CESIlE1C8IE DE SEBMICE I. hereby certify that copies of CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP) MOTION FOR ADDITIONAL DISCOVERY were served by deposit in the U.S. Mail, first class postage paid to the following individuals and entities on the 29th day of March 1984. Charles Bechhoefer, Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen. Atomic Safety and Licensing Board State of Texas U.S. Nuclear Regulatory Commission Environmtl. Protection Washington, D.C. 20555 P. O. Box 12548, Capitol Sta. Austin, Texas 7S711 Dr. James C. Lamb, III Administrative Judge Robert G. Perlis, Esquire 313 Woodhaven Road Office of the Exec. Leg. Dir. Chapel Hill, North Carolina 27514 U.S. Nuclear Regulatory Comm. j Washington, D.C. 20555 Ernest E. Hill 7 Administrative Judge Jack R. Newman, Esquire l Hill: Associates 1025 Connecticut Avenue, N.W. l 210 Montego Drive Washington, D.C. 20036 Danville, California Melbert Schwar=, Esquire i Baker and Botts Mrs. Peggy Buchorn 300 One Shell Plaza l - Executive Director, C.E.U. Houston, Texas 77002 ) Route 1, Box 1684 l Brazoria, Texas 77422 Atomic Safety and Licensing Bd. U.S. Nuclear Regulatory Comm. William S. Jordan, III, Esq. Washi'ngton, D.C. 20555 l 7 Harmon, Weiss & Jordan ! - 2001 S Street, N.W., Suite 430 Atomic Saf ety and Licensing Washington, D.C. 20009 Appeal Board U.S. Nuclear Regulatory Comm. Pat Coy Washington, D.C. 20555 j 5106 Casa Oro San Antonio, Texas 78233 Docketing and Service Section I Office of the Secretary l U.S. Nuclear Regulatory Comm.

                                      /   /,                         Washington. D.C. 20555

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