ML19210E951
| ML19210E951 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/04/1979 |
| From: | Franklin W BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912130313 | |
| Download: ML19210E951 (27) | |
Text
. .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S
HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S $ 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S
(South Texas Project, Units Nos. S 1 and 2)
APPLICATION FOR ISSUANCE OF SUBPOENAS Houston Lighting and Power Company, pursuant to 10 C.F.R.
SS2.740, and 2.741, applies for the issuance of the attached Sub-poenas, which call for a deposition requiring the attendance of the party listed, and for production of documents. The testimony and document production sought encompasses, but is not limited to, the testimony to be given in the instant proceeding, interest in and awareness of nuclear power projects, interconnections and operations involving interstate systems and the Texas Interconnected Systems, bulk alectric power supply, transmission planning, and fuel supply for electrical generation of electricity.
1551 242 Subpoenas (1) North Bardell, City of College Station (2) Lorence Bravenec, City of College Station (3) Keeper of the Records, City of College Station 7912130
Respectfully submitted, Dated: December 4, 1979 A,3%-
]
7.
g.
2, _,
Attorney for Houston Lighting
& Power Company Baker & Botts 3000 One Shell Plaza Houston, Texas 77002 Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 9
1551 243
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S
HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S
(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: Keeper of Records City of College Station P. O. Box 9960 1101 Texas Avenue College Station, Texas 77840 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act, as amended, and 10 C.F.R. S2.720, .t.o make. available Ramada Inn, for inspection and copying at the 410 ,Sout,h ,Texa,s Aven,ue in the City of Colle.ge. S.ta.ti.on., .TX on the 12.th. day of D.ec,embe.r
. l.9 7.9 a t L: 3.0 PM , the document (s) or object (s) described in the attached schedule, and to appear at such time to testify by deposition on oral examination in the above-antitled action as to the records of the City of College Station, and the manner of production of documents under this Subpoena.
1551 244
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
. . . . . . ., 19. .
J. Gregory Copeland Attorney for Houston Lighting
& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 7 20 ( f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or reqL?res evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
1551 245
SCHEDULE TO SUBPOENA
- 1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &
Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power
& Light Company; and any communications with any of the aforementioned entities.
- 2. All documents provided to or received from the U.S.
Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.
Department of Justice or U.S. Nuc' lear Regulatory Commission.
- 3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.
- 4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.
- 5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Scuthwest Power Pool, and/or (2) Western Systems Coordinating Councul.
- 6. All documents referring or relating to or setting for any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
1551 246
- 7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for City of College Station since January 1, 1973.
- 8. All documents referring or relating to or setting forth each transmission study developed by or for the City of College Station in connection with any of the bulk power supply plans covered in item number 7 above.
- 9. All documents referring or relating to or setting forth correspondence or contracts between City of College Station and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
- 10. All documents referring or relating to or setting forth any correspondence or contracts between City of College Station and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
- 11. All documents referring or relating to or setting forth any aspect of the decision of the City of College Station to change its wholesale supplier from the City of Bryan to Gulf States Utilities, including all engineering, economic, or other studies.
9 1551 247
Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.
Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c)' identity of author and addresses; *
(d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, repgrts, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1551 248
or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
1551 249 D
RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on
. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .
. . . . . . . . . . served it on the within named. . . .
. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.
Dated . . . . . . . . . 19. . . By . . . . . . . . . . .
Service Fees Travel. . . . . . . . . . . . . $
Services. . . . . . . . . . . . $ .
Total. . . . . . . . . . . . .. S Subscribed and sworn to before me, a . . . . . . . .
this. . . . . day of. . . . . . . . . . ,, 19. . .
1551 250
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S
HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S
(South Texas Project, Units Nos. S ,
1 and 2) S SUBPOENA TO: Lorence Bravenec Mayor City of College Station P. O. Box 9960 1101 Texas Avenue College Station, Texas 77840 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, .
to appear at the Ramad,a , Inn,, 4,10, S,ou,th, T,ex,as, AVin'the City o f C,ol,le,ge, S,tati,on,, ,TX on the 14 t,h . . day of D,e c,e mb e,r ,, 1,97,9 at .9:.3a AM (and thereaf ter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.
1551 251
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
. . . . . ., 19. .
J. Gregory Copeland Attorney for llouston Lighting
& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
1551 252
SCHEDULE TO SUBPOENA
- 1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &
Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power
& Light Company; and any communications with any of the aforementioned entities.
- 2. All documents provided to or received from the U.S.
Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.
Department of Justice or U.S. Nuclear Regulatory Commission.
- 3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.
- 4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.
- 5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.
- 6. All documents referring or relating to or setting for any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
1551 253
- 7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for-City of College Station since January 1, 1973.
- 8. All documents referring or relating to or setting forth each transmission study developed by or for the City of College Station in connection with any of the bulk power supply plans covered in item number 7 above.
- 9. All documents referring or relating to or setting forth correspondence or contracts between City of College Station and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
- 10. All documents referring or relating to or setting forth any correspondence or contracts between City of College Station and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
- 11. All documents referring or relating to or setting forth any aspect of the decision of the City of College Station to change its wholesale supplier from the City of Bryan to Gulf States Utilities, including all engineering, economic, or other studies.
1551 254 -
8
~
Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.
Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c)' identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1551 255
or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
1551 256
- D
RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on
. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .
. . . . . . . . . . served it on the within named. . . .
. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.
Dated . . . . . . . . . 19. . . By . . . . . . . . . . .
Service Fees Travel. . . . . . . . . . . . . $
Services. . . . . . . . . . . . $
Total. . . . . . . . . . . . .. $
Subscribed and sworn to before me, a . . . . . . . .
this. . . . . day of. . . . . . . . . . ., 19. . .
1551 257
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S
HOUSTON LIGHTING & POWER COM ?ANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPIRY S S
(South Texas Project, Units Fos. S 1 and 2) S S[B1'OENA TO: North Bardell City Manager City of College Station P. O. Box 9960 1101 Texas Avenue College Station, Texas 77840 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, to appear at the R,am,ad,a ,In,n ,, 4,10, Sou,th, Tex,as, A[j *the City of College. Station TX. on the . 13tn. . day of pepepbp r, 19,79 at 9:30. AM (and thereaf ter from day to day, if necessary) .o testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.
1551 258
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
. . . . . . ., 19. .
J. Gregory Copeland Attorney for Houston Lighting
& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 7 20 ( f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
1551 259
SCHEDULE TO SUBPOENA
- 1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &
Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power
& Light Company; and any communications with any of the aforementioned entities.
- 2. All docuuents provided to or received from the U.S.
Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.
Department of Justice or U.S. Nuclear Regulatory Commission.
- 3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and. Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.
- 4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.
- 5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest '
Power Pool, and/or (2) Western Systems Coordinating Councul.
- 6. All documents referring or relating to or setting for any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
1551 260
- 7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for City of College Station since January 1, 1973.
- 8. All documents referring or relating to or setting forth each transmission study developed by or for the City of College Station in connection with any of the bulk power supply plans covered in item number 7 above.
- 9. All documents referring or relating to or setting forth correspondence or contracts between City of College Station and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
- 10. All documents referring or relating to or setting forth any correspondence or contracts between City of College Station and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
- 11. All documents referring or relating to or setting forth any aspect of the decision of the City of College Station to change its wholesale supplier from the City of Bryan to Gulf States Utilities, including all engineering, economic, or other studies.
1551 261
Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.
Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.
If you claim that any document requested hereu der is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; -
(c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilogo; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors ' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1551 262
or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
1551 263 e
9
RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on
. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .
. . . . . . . . . . served it on the within named. . . .
. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.
Dated . . . . . . . . . 19. . . By . . . . . . . . . . .
Service Fees Travel. . . . . . . . . . . . . $
Services. . . . . . . . . . . .$
Total. . . . . . . . . . . . .. $
Subscribed and sworn to before me, a . . . . . . . .
this. . . . . day of. . . . . . . . . . ., 19. . .
155-1 264
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
HOUSTON LIGHTING & POWER COMPANY ) Docket Nos. 50-498A et al. ) 50-499A
)
)
(South Texas Project, Units 1 )
and 2) )
)
TEXAS UTILITIES GENERATING COMPANY ) Docket Nos. 50-445A et al. ) 50-446A
)
(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the foregoing:
Application of Issuance of Subpoenas to North Bardell, Lorence Bravenec, and Keeper of the Records of the City of College Station, were served upon the following persons, by hand'*, or by deposit in the United States Mail, first class postage prepaid, this 4th of December, 1979.
bik225 1551 265
- Marshall E. Miller, Esquire Frederic D. Chanania, Esquire U.S. Nuclear Regulatory Commission Roy P. Lessy, Jr., Esquire Washington, D.C. 20555 Michael B. Blume, Esquire U.S. Nuclear Regulatory Commission Michael L. Glaser, Esquire Washington, D.C. 20555 1150 17th Street, N.W.
Washington, D.C. 20555 Roff Hardy Chairman and Chief Lxecutive
- Sheldon J. Wolfe, Esquire Officer U.S. Nuclear Regulatory Commission Central Power and Light Company Washington, D.C. 20555 Post Office Box 2121 Corpus Christi, Texas 78403 Atomic Safety and Licensing Appeal Board Panel G. K. Spruce, General Manager U.S. Nuclear Regulatory Commission City Public Service Board Washington, D.C. 20555 Post Office Box 1771 San Antonio, Texas 78203 Chase R. Stephens, Supervisor (20)
Docketing and Service Branch Mr. Perry G. Brittain U.S. Nuclear Regulatory Commission President Washington, D.C. 20555 Texas Utilities Generating Company 2001 Bryan Tower Mr. Jerome D. Saltzman Dallas, Texas 75201 Chief, Antitrust and Idenmity Group R. L. Hancock, Director U.S. Nuclear Regulatory Commission City of Austin Electric Utility Washington, D.C. 20555 Post Office Box 1086 Austin, Texas 78767 J. Irion Worsham, Equire Merlyn D. Sampels, Esquire G. W. Oprea, Jr.'
Spencer C. Relyea, Esquire Executive Vice President Worsham, Forsyth & Sampels Houston Lighting & Power Compnay 2001 Bryan Tower, Suite 2500 Post Office Box 1700 Dallas, Texas 75201 Houston, Texas 77001 Jon C. Wood, Esquire Joseph Gallo, Esquire Matthews, Nowlin, Macfarlane Robert H. Loeffler, Esquire
& Barrett Isham, Lincoln & Beale 1500 Alamo National Building 1050 17th Street, N.W.
San Antonio, Texas 78205 Suite 701 Washington, D.C. 20036 Charles G. Thrash, Jr., Esquire E. W. Barnett, Esquire Michael I. Miller, Esqurie Theodore F. Weiss, Esquire David M. Stahl, Esquire J. Gregory Copeland, Esquire Martha E. Biggs, Esquire Baker & Botts James A. Carney, Esquire 3000 One Shell Plaza Sarah Welling Houston, Texas 77002 Isham, Lincoln & Beale One First National Plaza R. Gordon Gooch, Esquire Suite 4200 Steven R. Hunsicker, Esquire Chicago, Illinois 60603 Baker & Botts 1701 Pennsylvania Avenue Don R. Butler, Esquire Washington, D.C. 20006 Sneed, Vine, Wilkerson, Selman
& Perry Post Office Box 1409 Austin, Texas 78768 1551 266
b Jerry L. Harris, Esquire W.S. Robson Pichard C. Balough, Esauire Ganeral Manacer City of Austin South Texas Electric Cocoerative, Inc.
P.O. Box 1088 Route 6, Building 102 Austin, Texas 78767 Victoria Regional Airport Victoria, Texas 77901 Josenh B. Knotts, Jr., Esquire Nicholas S. Reynolds, Esquire Robert C. McDiarmid, Esquire Debevoise & Liberman Robert A. Jablon, Esquire 1200 17th Street, N.W. Marc R. Poirier, Esquire Washington, D.C. 20036 Spiegel & McDiarmid 2600 Virginia Avenue, N.W.
Don H. Davidson Washington, D.C. 20037 City Manager City of Austin Kevin B. Pratt P.O. Box 1088 . Texas Attorney General's Office Austin, Texas 78767 P.O. Box 12548 Austin, Texas 78711 Jay Galt, Esquire Looney, Nichols, Johnson & Hays Filliam H. Burchette, Esquire 219 Couch Drive Frederick H. Ritts, Esquire Oklahoma City, Oklahoma 73102 Law Offices of Northcutt Ely Watergate 600 Building Knoland J. Plucknett Washington, D.C. 20036 Executive Director Committee on Power for the South- Tom W. Gregg, Escuire west, Inc. P.O. Box Drawer 1032 5541 East Skelly Drive San Angelo, Texas 76902 Tulsa, Oklahoma ,74135 .
Leland F. Leatherman, Escuire John W. Davidson, Esquire McMath, Leatherman & Woods, P.A.
Sawtell, Goode, Davidson & Tioilo 711 West Third Street 1100 San Antonio Savings Building Little Rock, Arkansas 72201 San Antonio, Texas 78205 Paul W. Eaton, Jr., Esquire Douglas F. John, Esquire Hinkle, Cox, Eaton, Coffield &
Akin, Gump, Hauer & Feld Hensley 1333 New Hampshire Avenue, N.W. 600 Henkle Building Suite 400 P.O. Box 10 Washington, D.C. 20036 Roswell, New Mexico 88201 David A. Dopsovic, Esquire Robert M. Rader, Esquire Frederick H. Parmeter, Esquire Conner, Moore & Corber Susan B. Cyphert, Esquire 1747 Pennsylvania Avenue, N.W.
Nancy A. Luque, Esquire Fashington, D.C. 20006 Energy Section Antitrust Division U.S. Department of Justice W.N. Foolsey, Esquire P.O. Box 14141 Dyer and Redford Washington, D.C. 20044 1030 Petroleum Corous Christi, Texas 78474 '
Morgan Hunter, Esquire Bill D. St. Clair, Esquire McGinnis, Lockridge & Kilgore Fifth Floor Texas State Bank Building 1551 267 000 Congress Avenue -
Austin, Texas 78701
Donald M. Clonents, Esquire Gulf States Utilities Company P.O. Box 2951 Deaumont, Texas 77704 Dick Terrell Brown, Esquire 800 Milan Building San Antonio, Texas 78205 Anne P. Ilo d g d o n , Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1551 268 9