ML19225B792
| ML19225B792 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 07/03/1979 |
| From: | Harris J, Lessy R JUSTICE, DEPT. OF, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7907260038 | |
| Download: ML19225B792 (89) | |
Text
_
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
UOUSTON LIGHTING AND POWER
)
Docket Nos. 50-498A CO., et al.(South Texas
)
'n-499A Project, Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY (Comanche Peak Steam )
50-446A Electric Station, Units 1
)
and 2)
)
)
JOINT APPLICATION FOR ISSUANCE OF SUBPOENAS The Department of Justice and the Staff of the Nuclear Regulatory Commission, pursuant to 10 CFR S2.720, heteby make a joint application for the issuance of subpoenas, identified hereinafter and attached to this application.
These subpoenas call for the giving of testimony and the production of documents which are relevant to the issue of competition ir. the electric utility industry in the State of Texas and surrounding states, the structure of the electric utility industry in and reasonably adjacent to the State of Texas, accers to nuclear power plants, other sources of generation and transmission and the interstate 368 256 790726:,csy N
s.._._
\\
Versus intrastate operation of electric utilities in and around the State of Texas.
All of the depositions listed in this application are scheduled to take place before the prese.t October 30, 1979 close of discovery.
Subpoenas for Deposition 1.
J.B. Swinke, Tex-La Cooperative 2.
William Marquardt, Texas Electric Service Company 3.
R.L. Evans, Houston Light _ng and Power Company 4.
Donald D.
Sykora, Houston Lighting and Power Company 5.
D.E. Simmons, Houston Lighting and Power Company 6.
Harold Arnold, City Public Service Baard of San Antonio 7.
W.F.
Dreiss, City Public Service Board of San Antonio 8.
Jesse B.
Poston, City Public Service Board of San Antonio 9.
E.
Bendele, City Public Service Board of San Antonio
- 10. Art Wilson, City Public Service bcard of S:n Antonio
- 11. J.K.
Spruce, City Public Service Board of San Antonio
- 12. Robert Mecke, City Public Service Board of San Antonio 13.
F.W.
Payett, City Public Service Board of San Antonio 368 257
- 14. H.L.
Petersor., City of Austin Electric Utility Department
- 15. E.L.
Rummel, City of Austin Electric Utility Department 16.
R.L.
Hancock, City of Austin Electric Utility Department
- 17. Joel rogers, Texas Municipal Power Authority
- 18. Edward Geer, Texas Municipal Power Auchority Authority
- 19. Sim Gideon, Lower Colorado River Authority
- 20. Ralph Heyler, Lower Colorado River Authority Subpoenas for the Production of Documents 1.
R.D.
Ledbetter, Texas Electric Service Company 2.
William Marquardt, Texas Electric Service Company 3.
D.E. Simmons, Houston Lighting and Power Company 4.
Art Wilson, City Public Service Board of San Antonio 5.
J.K.
Spruce, City Public Service Board of San Antonio 6.
Robert Mecke, City Public Se vice Board of San Antonio 7.
F.W.
Payett, City Public Service Board of San Antonio 8.
H.L. Peterson, Houston Lichting and Pcwer Company 9.
R.L. Hancock, City of Austin Electric Utility Department 308 258
- 10. Sim Gideon, Lower Colorado River Authority
- 11. Ralph Heyler, Lower Colorado River Authority
.Ni h
a Roy PL Lessy, J r.V Jydith L.
H a r r is' Michael B.
Blume Susan B. Cyphert Counsel for NRC Staff Ronald H.
Clark U.S. Nuclear Regulatory Frederick H.
Parmenter Commission Attorneys, U.S. Dept.
Washington, D.C.
20555 of Justice Antitrust Division Washington, D.C.
20530 July 3, 1979 368 259
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SA?ETY AND LICENSING BOARD
)
In the Matter of
)
)
HOUSTON LIGHTING AND POWER
)
Docket Nos. 5C-498A CO.,
et al.(South Texas
)
50-499A Project, Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY (Comanche Peak Steam )
50-446A Electric Station, Units 1
)
and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that service of the foregoing JOINT APPLICATION FOR ISSUANCE OF SUBPOENAS has been made on the following parties listed hereto this 3rd day of July, 1979, by depositing copies tereof in the United States mail, first class, postage prepaid,and where asterisks appear, service has been made by hand.
Marshall E.
Miller, Esquire
- Atomic Safety and Licensing Chairman Appeal Board Panel Atomic Safety & Licensing Board U.S. Nuclear Regulatory Panel Commission U.S. Nuclear Regulatory Washington, D.
C.
20555 Commission Washington, D.
C.
20555 Richard S. Salzman, Esquire U.S. Nuclear Regulatory Michael L. Gl.ser, Esquire
- Commission 1150 17 th S tree t, N.W.
Washington, D.
C.
20555 Washington, D.
C.
20036 Jerome E.
Sharfma:., Esquire Sheldon J. Wolfe, Esquire
- U.S. Nuclear Regulatory Atomic Safety & Licensing Board Commission Panel Washington, D.
C.
20555 U.S. Nuclear Regulatory Commission Chase R.
Stephens, Secretary
- Washington, D.
C.
20555 Docketing and Service Branch U.S. Nuclear Regulatory Samuel J. Chilk, Secretary Commission Office of the Secretary of the Washington, D. C.
20555 Commission U.S. Nuclear Regulatory Jerome Saltzman Commission Chief, Antitrust and Washington, D.
C.
20555 Indemnity Group U.S. Nuclear Regulatory iommission 368 260 Washington, D. C.
205s5
~
Roff Hardy Michael I. Miller, Esquire Chairman and Chief Executive Richard E.
Powell, Esquire Officer David M.
Stahl, Esquire Central Power and Light Thomas G.
Ryan, Esquire Company Martha E. Gibbs, Esquire P. O. Box 2121 Isham, Lincoln & Beale Corpus Christi, Texas 78403 One First National Plaza Chicago, Illinois 60603 G.
K. Spruce, General Manager City Public Service Board Roy P.
Lessy, Esquire P.O. Box 1771 Michael Blume, Esquire San Antonio, Texas 78203 U.S. Nuclear Regulatory Commission Perry G.
Brittain Washington, D.
C.
20555 President Texas Utilities Generating Jerry L.
Harris, Esquire Company City Attorney, 2001 Bryan Tower Richard C. Balough, Esquire Dallas, Texas 75201 Assistant City Attorney City of Austin R.L.
Hancock, Director P.O. Box 1088 City of Austin Electric Austin, Texas 78767 Utility Department P. O.
Box 1088 Robert C. McDiarmid, Esquire Austin, Texas 78767 Robert A. Jablon, Esquire Spiegel and McDiarmid G.
W.
Oprea, Jr.
2600 Virginia Avenue, N.W.
Executive Vice President Washington, D.
C.
20036 Houston Lighting & Power Company Dan H. Davidson P. O. Box 1700 City Managar Houston, Texas 77001 City of Am, tin P. O.
Box 1088 Jon C. Wood, Esquire Austin, Texas 78767 W.
Roger Wilson, Esquire Matthews, Nowlin, Macfarlane Don R.
Butler, Esquire
& Barrett 1225 Southwest Tower 1500 Alamo National Building Austin, Texas 78701 San Antonio, Texas 78205 Joseph Irion Worsham, Esquire Joseph Gallo, Esquire Merlyn D. Sampels, Esquire Richard D.
Cudahy, Esquire Spencer C.
Relyea, Esquire Robert H.
Loeffler, E3 quire Worsham, Forsythe & Sampels Isham, Lincoln & Beale 2001 Bryan Tower, Suite 2500 Suite 701 Dallas, Texas 75201 1050 17th S treet, N.W.
Washington, D.
C.
20036 Joseph Knotts, Esquire Nicholas S.
Reynolds, Esquire Debevoise & Liberman 1200 17 Street, N.W.
Washington, D.
C.
20036 368 261
Douglas F. John, Esquire R. Gordon Gooch, Esquire Akin, Gump, Hauer & Feld John P. Mathis, Esquire 1333 New Hampshire Avenue, N.W.
Baker & Botts Suite 400 1701 Pennsylvania Avenue, N.W.
Washington, D. C.
20036 Washington, D.
C.
20006 Morgan Hunter, Esquire Robert Lowenstein, Esquire McGinnis, Lochridge & Kilgore J.A.
Bouknight, Esquire 5th Floor, Texas State Bank William J.
Franklin. Esquire Building Lowenstein, Newman, Reis, 900 Congress Avenue Axelrad & Toll Austin, Texas 78701 1025 Connecticut Avenue, N.W.
Washington, D.
C.
20036 Jay M. Galt, Esquire Looney, Nichols, Johnson E.
W.
Barnett, Esquire
& hayes Charles G.
Thrash, Jr., Esquire 219 Couch Drive J. Gregory Copeland, Esquire Oklahoma City, Oklahoma 73101 Theodore F. Weiss, J r., Esquire Baker & Botts Knoland J.
Plucknett 3000 One Shell Plaza Executive Director Houston, Texas 77002 Committee on Power for the Southwest, Inc.
Kevin B.
Pratt, Esquire 5541 East Skelly Drive Assistant Attorney General Tulsa, Oklahoma 74135 P.O.
Box 12548 Capital Station Jonn W. Davidson, Esquire Austin, Texas 70711 Sawralle, Goode, Davidson t Tioilo Frederick H.
Ritts, Esquire 1100 San Antonio Savings Law Offices of Northcutt Ely Building Watergate 600 Building San Antonio, Texas 78205 Washington, D.C.
20037 W.
S.
Robson Donald M. Clements, Esq.
General Manager Gulf States Utilities Company South Texas Electric P.O.
Box 2951 Cooperative, Inc.
Beaumont, Texas 77704 Route 6, Building 102 Victoria Regional Airport Donald M.
Clements, Esq.
Victoria, Texas 77901 Gulf States Utilities Company P.O.
Box 2951 Robert M.
Rader, Esquire Beaumont, Texas 77704 Conner, Moore & Corber 1747 Pennsylvania Ave., N.W.
^
~
Washington, D.C.
20006 M
b<
Judi*'th L ris Attorney W.N.
Woolsey, Esquire Energy
,n Dyer and Redford Antitrus; 1 vision 1030 Petroleum Tower Department of Justice Corpus Christi, Texas 78474 368 262
- - -... ~.
Civil Subpoena To Testify Hittileb Bf. ales of America gi NUCLEAR REGULATORY COMMI.9SION 1
y in the mntier of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS, 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
)and 2)
J.
B. Svinke Tex-La Electric Cooperative P.O. Box 398 Quitman, Texas YOU ARE IIEREBY COMMANDED to appear
.t noom... 8.C.f.r... A A.9.9...C.9.EE.e.r.cs..s,t3,rg,9,t,,,,,,,,,,,,,,,
i n the c i ty o r.......D,a,,1, },a,s,,,,,'fe,3 a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the...P..%...... day of..... AMun t............19.29....a t.......Qn R....o'c1nck P A1.
to testify
~
in the alme.
cntitled action i (and thereaf ter from day to day,.
if necessary).
P002 ORIGML IlY ORDl;H OF Tile ATthtlC SAFETY AND LICENSING llOAl(D IfY Susan B. Cyphert Ronald H.
Clark Attornes int Anntrust Division
- ...................19.......
t'nined.staten Department of Juntice
. Wanhinston.(D.b. 20530hnne. 2 2.).. 2.24..6422/6. 61 368 263 Telet (202) 724-6616 790726 10 C.V.R. 2.720 (n vresidine officer or, it he in unnvailabic, Ihe On motion onade promptly, and in nouv event Comminn!nn mnv til nunnh or modify the nuh.
at or before the time specified in'the nubpoena poena if it is unreasonable or requi.re evidence for complianec by, the person to whorn the sub.
not relevant to any matter in issue, or ta, w poena is directed, and on notice to the party at dition denial of the motion on just and reasonable schase lastance the subpoena was issued, the terms.
Civil Subpoena "o Testify Ettilch 91.a.lta of Aitterint 8
NUCLEAR REGULATORY COMMISSION 1
Y In the nmtter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 98A CENTRAL POUER AND LIGHT COMPMY 50-499A (South Texas Project, Units Nos.
and T.)
)
R.
L.
Evans Houston Lighting and Power Company P.O.
Box 1700 Houston, Texas 77001 YOU ARE HEREBY COMMANDED to appear
~
.t noom....... l.2,g,g,9,,,,,,n 3,,,n,y,s,k,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
i n t he c ty o f............H..o..u..s.. t..o.. n..,....T..e..x..a...s....................................................
i on the.. l.9.t.h..... day of.....S.e.R.t,q,@.9.F.......19.2.9....at.... 9..:. 3,0,,,,,o. clock A.M.
to testify in the above entitled action - (and thereafter fru.a day to day, if necessary).
a llY Olti)Mit Ol' TilM ATOMIC SAFETY AND I,trENSING ltOAl(D IfY Susan B. Cyphert Ronald H.
Clark Attornes for Anlatrust Dn inion l'neted %tatea Department of.luatice
.....'.s....................19.......
\\\\'a u hirtglon,(D.('. 20$30202.)..224..6422/6361 reteponne..
(202) 724-6616 368 264 10 C.Y.lt. 2.72to t D presiding ollicer or. If he in unnvailable, the on motion made promplir, nnel in nur event Comminnlan mav til nunnh or modify the sub.
at or before the time specificJ in'the subpoena rocna if it in sonreasonahle or requires evidence for compliance by the person to schom the sub~
not relcL ant to ony matter in innue, or 42) con-poenn in efirected, and on notice to the party at dition denial of the motion on just and reasonable whnne innlance the suhrnenn un innued, the terme.
Civil Subpoena To Testify
~
tinilch Bh. des of America t
NUCLEAR REGULATORY COMMI.9SION 2
Y in the tuntter or:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 98A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Neis.
and 2) p Donald D.
Sykora Houston Lighting and Power Company P.O.
Box 1700 Houston, Texas 77001
--YOU ARE IIEREin' COMMANDED to appear a t Room...... 1. 2. 0. 0. 0..,... 5. 1. 5.....R..u..s..k..................................
i n t h e c i ty o f........H..o.. u..s..t..o..n...,...T..e...x..a..s.......................................................
o n the...... A.Q.tr.h da y o f.....S.9.P.h RWh.QI....... 19. 2 S....n t...... ), ;. 3.C...o'c l oc k P. M.
to testify in d a nlme entitled action (and thereaf ter from day to cay, if necessary).
ilY OltDMit OF TitM ATOMIC sal'ETY AND 1.1 CENSING '40Altl)
IN Susan B. Cypher
- Ronald H.
Clark Antonwr frr Anternat Division t'nnsed. state. Department of.sustice
......................19.......
wa~hinaron.(v.c. 2053a202.1.. 2.2f.64.72/6361 reicpi.nne..
(202) 724-6616 368 g}
10 C.V.R. 2.720 (0 presidinx officer or, if he in unnvailable, m
on unntion made pravpth. nnd in wov et ent Commin ninn mnv til qunnh or modufy the aust>.
at or befare the tina specified in'the subpoena poena if it is unreas onable or reutuires evidence for compiinner h.x the perso't to schn'rt the sub.
not reles' ant to arny r9 atter in in n ue, or 120 con.
poenu in directed and on notice to the party at dition denial of the motion on just and reancnable schnne instance the subpoena scan innued, the terme.
a
~
Civil Subpoena To Testify 3!!nineh 9f.a,les of America NUCLEAR REGULATORY COMMI.9SION 1
Y In the inatter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 98A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
1 and 2)
TO Harold ?rnold City Pubu c. Service Board of San I.ntonio P.O.
Box (7'l 145 Navarro Street San Antonio, Texas 78296 YOU ARE llEREBY COMMANDED to appear at Room...G...1. 3..t... 6. 6. 5....E.....D...u..r..a..n..ilo... B..l..v..d...
i n t he c i ty o r......S,a,n,,,g,t,9,n,i,9 7,,,,Tg,x,a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the... 2,,4,,t h... day of.....SS.P.t,9,@g,r,,,,,,,,19,2 3,,,,a t,,,,1,0,;,3,,0...o' clock A. M.
to testify in the above entitled action (and thereaf ter from day to day, if necessary).
a llY OftDBit Ol' TitM ATOMIC sal'ETY AND 1,1 CENSING llOAl(D HY Susan B.
Cyphert Ronald H.
Clark A tt.ornes (nr,\\ ntstrun t Dwision t nnea.staic. Department of.lustice
~~~~~~~"""""'19'"""'
. ua.hinsaon,(n.c. 20s30202.1.. 22.d:.6422/63 61 Tciephone..
(202) 724-6616 10 C.V.it. 2.720 (0 presidine otlicer or, if he in unnva.'Intdc. the On unation orcade prompliv, arn' a n v event Comminninn mas til qunnh or modtfy the nub.
at or before t re time specil.'e J the nutparna poena if it in unreasonable or requires evidence i
[or compliance h.x the pesson 'o scho n the std" not reltt' ant to any matter in innue, or (29 con.
poenu in directed, artd on nu.ce t~ .e party at dision denial of the motion on just and reasonabic schose instance the subpoco*. e,u'
..ned, the terme.
Civil Subpoena To Testify Mittileb Bl.a,les of Amerita NUCLEAR REGULATORY COMMISSION 1
y in the matter of:
HOUSTON LIGHTING A POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS, 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2)
)
W.
F.
Dreiss City Public Service Board of San Antonio-P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296
-~~YOU ARE IIEREHY COMMANDED to appear
~
.t Room........9..l.3.i...ss.s..p.,,..p,ur.9m9...M.Y.4.i........
i n t he c i ty o f....... E.a,n,,,An,,t g,9 ip, f,,,g,x,a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the....?.4.th... day of......S 99102h0 K.....19.2.9....at..... Al.i.3.Q.o' clock A. M.
to testify in the alzwe entitled action (and thereafter from day to day, if necessary).
IlY OltDMit Ol' Tile ATOMIC SAI'ETY AND I.! CENSING llOAl(D IfY Susan B. Cyphert Ronald H.
Clark hilournes [nr Antstrtant Dit'in ton
........*.*=...............I9........
('nif ed Siafra Defmrtment of. justice Y'anhin ton,(D.C. 20$30202.).. 2.24..Ed22/6 3 61 reics. Anne..(202) 724-6616 368 267 10 C.V.n. 2.720 tn presidina articer or, it he in unnvaitarde, ehc On unntlan made preumptly, nnd in nov vvent Comminnion may til qunnh or modify the anb.
at or before the time spa cified in'the subpoena poena if it in unreasonable or requires evidence c
for compliance by, the person to rehorn the sub-not relevant to any matter in innue, or (21 con-poena is diverted, and on notice in the party at dition denial of the motion on just and reasonable u hnne instance the suhporous wun issued, the terms.
F Civil Subpoena To Testify hineb E.a,,tes of Amerint NUCLEAR REGULATORY COMMISSION 1
s in the runtler of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 9 8 A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
,and 2)
Jesse B.
Poston City Public Service Board of San Antonio P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU ARE ilERERY COMMANDED to apocar a t Room.......G...1. 3...,... 6. 6. 5....E......D..u..r..a..n..g o.....B..l..v..d..
r.
i n t he c i ty o f... S.a,n,,,A n, t gn,i,g,,,,,Tf; 3,a.g......,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,............
on the....M..@.. day of.....S9P.t.9.Ulhf?K.......19.29....nt......T.V.Q.....o' clock P. M.
to testify in the alme entitled action (and thereaf ter from day to day, if necessary).
IlY OltDElt 01* Tile ATOMIC sal'ETY AND 1.lCENSING llOAltD IfY Susan B.
Cyphert
~
Ronald H.
Clark A ttarnes (nr A nistrust Divisinn t 'n tled Staten Department of.lustice
"**""""*"**"*'"*'}g""***
. \\tashirtxton,(U.f'. 20530202.)..2.24:.64.7.2/6361 Triert.nne..
(202) 724-6616
}{g
}fg 10 C.V.ll. 2.720 (D presidinit <!iirer or, if he is unnendable the On motion inade promptiv. nnd in ans event Commin ninn mn.v til qunnh or modsfy tior o ni.-
at or bc(nre the lin*c specified sn'the subparna (soenn if it is unreannnaldt or requires evidence (c. cc~plin tre by, tine persort to rehn*n the sede not reles ant to any matter in innue, or (21 con-poenu in directed, notd on nnlice to the party at dition denial of the motion on just and reasonable schau instanrc the subpoenn wun issued, the term s.
Civil Subpoena To Testify Iininth E.a.les of Amnira NUCLEAR REGULATORY COMMISSION 1
Y In the nintter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 98A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2)
O E.
Bendele City Public Service Board of San Antonio P.O. Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU ARE llEREbY COMMANDED to sp/.. 55.5,,,E, Durangg B1yd, ear at Room.... 9.T.l...
,7,,
.......................g.3.g...g.g.g.6..'6.'.1'5...".."..'..".."..'M...".."..'.'.".."..".."..".."..".."..'.'.".."..".."..".."..'.'."."..".
f in the c ity or.....................
on the. 2,4.$h..... day af..SfG.te.mbar.........19.2 9....at...J.:.3 Q.....o'elock P. M.
In testify in the ahwe entitled action 4 (and thereafter from day to day, if necessary).
llY OltDElt OF TilF. ATtB11C SAFETY AND !.! CENSING 140AllD HY Susan B.
Cyphert Ronald H.
Clark Attorner (nr A nistrust Dit'is ton t'ni ed seatc= 0eenrtmene of.:uaeaee
...........................I9.......
wa hanwon.(o.c. 20ssa202.1..2.24..64.72/6361 Tcicphone..
(202) 724-6616 368 269 10 C.Y.it. 2.720 (n presidine o((icer or. ll he in unnvailable. the On unation unnde promptly, and on n or cu,crut Comminnian may 41I quanh or modify the nub.
at or lefore the time specified in'the subpoena poena if it is sonreasonable or reqrsires evidence for complinstre by the pesson to schoon the sub-not relevant to any matter in isnue. or 128 con.
poena in riirected, and on notice to the party at dition denial of the motion on just and reasconable u hose instance the subpnena scan issued, the terme.
Civil Subocena To Testify Mini 2eb E.u.les of America t
NUCLEAR REGULATORY COMMISSION A
v in the mniter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER AND LI".T COMPANY 50-499A (South Texas Project, Units Nos.
)and 2)
E.
L.
Rumel City of Austin Electric Utility Department P.O.
- ~ ~ - - ~ ' ~YOU ARE ilEREBY COMMANDED to appear a t noom.... 7. 5,,2,,,,,,3,0,0...D).9.t...F.th..#.t.r.e.9.t...............
i n t h e c i t y o f.......... A...u..s..t..i..n...,....T..e. x..a..s.......................................................
on the.... 9.t,h.....duy of.... 9.c,go,yg,r...........19.2.9....at..gn,e,,,,,,,,,o c1ock P.M.
to testify in the alzwe entitled action (and thereaf ter from day to day, if necessary).
ilY ORDim 01' TilK ATOMIC SAFETY AND 1.1 CENSING llOAltD m*
Susan B.
Cyphert Ronald H.
Clark hitornt*v [nr Anistrust Divssion l'nsted Staten Urpartment of.lun ice
...........................,19........
. Washinnton.b.Q. 20$3Cu2).. 22.4..64.72/6 3 61 (202) 724-6616 368 2/0 Teicphone..
10 C.V.n. 2.720 tD presidina officer or, if he in unntaitalde. the On ennlinn made promplls, und in nns eveng Comminninn mnv til qunnh or modify the nule at or before the time specified in'th. subpoena poena f(It is unreasonable or requires evidence for complinnre 97 the pesson to n.hn n the sule not relevant to any matter in innue, or (21 con.
por.a in directed, and on notice to the party at dition denial of the motion on just and reaso~nble schase instance the subpoenn uun issued, the terms.
,a
e Civil Subpoena To Testify Minileb E.a,les of America NUCLEAR REGULATORY COMMISSION 1
y in the matter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2) 1 Joel Rogers Texas Municipal Ptwer Authority 2225 E.
Randol Mill Road Arlington, Texas 76011 YOU ARE HEREBY COMMANDED to appear a t Room.... 8..C. 6...,...1.1. 0. 0....C.. o...m..m..e..r..c..e.....S..t..r..e..e..t...............
i n t he c i ty or................ 9.a,1,1, a g,,,,,,T,9,x,a, g,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.... 2,Q,t,h.. day of.... 9.c,t,o h9.Y...........19.2 9....et....@.n e.....o' clock A. M.
to testify in the alzwe entitled action, (and thereafter from day to day, if necessary).
ilY OltDElt Ol' Tile ATOMIC sal'ETY AND 1.fCENSING llOAltD in' Susan B.
Cyphert Ronald H.
Clark Attornn for Arutrust Division
(*nited Staten Department of Justice
- ""*""""*"*"""*'}g'""'
. washinaron,(o.c. 20s30202)..224..6422/6361 Telephnne..
(202) 724-6616
- 3gg, y}
10 C.V.lt. 2.720 (n presidinot o!!icer or, if he in unnendnble, the On onnlinn onade prrumptly, nnut in n*rv recent Comminninn mnv til nunnh or modify the nub-at or beft re the time specified en'the subpoena poena if it is unreasonable or requires evidence
[or complinnee by the person to echam the sub.
not relevant to any matter in issue, or (29 con.
poena in directed, and on notice to the party at dition denial of the motion on just and reasonable schone inntonce the suhporous won insued, the terms.
.-=,--e
-. - =
e Civil Subpoena To Testify Ltileb Eules of Anterica NUCLEAR REGULATORY COMMISSION 1
y in the matter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIM and DOCKET NOS. 50-498A CENTRAL POWER AND LIGHT COMP 7.NY 50-499A (South Texas Project, Units Nos.
and 2) 0 Edward Geer Texas Municipal Power Authority
.2225 E.
Randol Mill Road Arlington, Texas 76311
~~~-YOU ARE llEltEBY COMMANDED to appear at noom...3.95.,..1199... 9.m9x.9.9.. 0.t r.99.t...............
.i n t h e e t y o f.......D..a.. l.. l.. a...s..,....T..e..x.. a...s........................................................
i on the.. 7.E.t h....duy of.....Q.GiQhQ K.......... 19.2.9....at.....Qan......o' clock P Jt.
to testify in the niinve entitled action. (and thereaf ter from day to day, if necessary).
ilY ORDl;lt OF TilF. ATOMIC SAFETY AND I.lCENSING HOARD m*
Susan B. Cyphert Ronald H.
Clark AtInrnes for Antstrunt Divinion
..e.*..***.***=..........s19.......
t'nited Staten Department of.luatice
. wa.hinaron.(q.c. 20530reter hone...d2.).. 2.24:.642.2/6 3 61 g,
}'[ 2 (202) 724-6616 10 C.V H. 2.720 tD presidina ofliter or, if he in unnvadahtc. one on unation made prompris. nnd in any event Comminnian may ill quanh or motlify I'oe nub.
at or before the time specificJ Cn'tlu. subporna poena it it is unreasonable or requires evidence for compliance by, the person 80 CLh0M lhe sub*
nUI rC$tVQnt to any mQtter in $ssue, or (21 Cone poennt is tilrated, and on notice to the party at dition denial of the motion ors just and reasonable schane ins <ance the suhporna stan issued, the terms.
CIVII. SUltPOEN A TO PROlH CE IMK'UMENT OH OllJECT
%tileb Bl.a,,les of Amerita NUCLEAR REGULATORY COMMISSION 2
Y In the inattur of:
HL"3 TON LIGHTING & POWER COMPANY
~
THE CITY OF SAN ANTONIO THE 7ITY OF AUSTIN and DOCKET NOS. 50-498A CENT. '. POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2;*
O R.D.
Ledbetter Texas Electric Service Company P.O.
Box 970 Fort Worth, Texas 76101 YOU AllE ilEREHY COMMANDED to appcc at noom.. 0.9.6,,,,,,1;,9,0,,,Cge,e r,7,e,,, s,t r,e,e,t,,,,,,,,,,,,,,,,
i n th e c t y o f......D...a..l..l..a..s.. f...T.. e...x..a..s.........................................................
i on the. 2.7.tM....duy of.... AM914,5.t.............19...~/.S..at..... 2.i.).9...o' clock A.M.
to testify in the alxwe entitled action and bring with you the document (s) or object (s) descritel in the attached schedule. (and thereaf ter from day to day, if necessary).
IlY ORDCit Ol' TilM ATOMIC SALT.TY AND I,IrENSING llOARD in' Susan B. Cyphert Ronald H.
C1 a rle Attarrres (nr A ntstrust Un in unn
"""""""*""""*"*39'""'
l'ntted.staten Department of.luntire u ashington. D,C. 20530 g
y}
Telephnne..(2.02.).. 724n 6432/6 3 61 y
(202) 724-6616 J
10 C.V.\\t. 2.720 (D presidiera. lliver nr. if he i< unnendnide. the On onation made prnmplis. nn l ire any es?cnt Commin n.nn mnv Ill qunnh or modify the nut-at or before the time spe ulsed in the onbporna Isoenn if it in untrannnable or requiren evidence for complinnre by, the person to whnw !.e sub=
not relen ant to any matter in innue, or (29 con.
F poena in diverted. and on entice to the party at dition denial of the motion on just and reasonabic
' whnne instance the subpnenn wun in nued, the terme.
SCHEDULE I.
DEFINITIONS 1.
" Document" means, without limiting the generality of its meaning, all original (or cooies where originals are unavailable) and non-identical cspies (whether different from originals by reason of nota.. ion 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 con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoir.g and any supporting, underlying or preparatory material.
2.
" interconnection" means a transmission line joining two or more power systems through which power produced by one can be usea by the other.
3.
"Eme. ;ency Interconnection" means an interconnection established to meet an emergency need.
4.
"GSU" means Gulf States Utilities Company.
5.
"HLP" means Houston Lighting & Power Company.
6.
"WTU" means West Texas Utilities Company.
7.
"TESCO" means Texas Electric Service Company.
8.
" CPL" means Central Power & Light Company.
9.
"TU" means Texas Utilities Company.
368 274
II.
CLAIM O{_ PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragreph(s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where tne documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
Should any questions arise concerning this subpoena, please contact Susan B.
Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Deparument of Justice P.O. Box 14141 Washington, D.C.
20044 368 275
DOCUF.ENTS TO BE PRODUCED
- 1. All documents which relate or refer, in any way, to:
(a) the Huffman interconnection with GSU; (b) a memorandum from R.D.
Ledbetter to the file, dated September 28, 1970, concern-ing an inquiry to HL&P about the Huffman interconnection with GSU; (c) two memoranda from R.D.
Ledbetter to the file, dated January 6, 1971 and Marco 25, 1971 respectively, corice r ning telephone communication with Frank Austin of HL&P relating to information about the Huffman interconnection with GSU; (d) a memorandum from R.D.
Ledbetter to the file, dated October 6, 1971 concerning a telephone communication to HL&P relating to information about the Huff-man interconnection with GSU.
- 2. All documents which relate or refer, in any way, to:
(a) existing or proposed interconnections between WTU and TESCO; (b) a memorandum from R.D.
Ledbetter to the file, dated September 7, 1967 concerning a proposed WTU-TESCO interconnection.
- 3. All documents which relate or refer, in any way, to:
(a) an interconnection between WTU and TESCO at Paint Creek; (b) a memorandum from Dale Scarth to R.D.
Ledbetter, dated May 14, 1971, con-cerning interconnections made between WTU and TESCO at Paint Creek; 368 2 716
(c) a letter from R.D.
Ledbetter to P.G.
Brittain, Dale Scar th, J.B.
- Robuck, and W.H. Harrison, dated June 24, 1971, concerning John Hume's drar't of a letter to Harry A. Poth; (d) a draft of a letter from R.D.
Ledbetter to Harry A.
Poth, dated June 1, 1971, relating to the WTU-TESCO intercon-nections; (e) a letter from Harry A.
Poth to R.D.
Ledbetter, dated August 24, 1972; (f) a letter from Hayden N. Smith to Harry A. Poth, dated June 27, 1972.
- 4. All documents which relate or refer, in any way, to:
(a) changes in TESCO's interconnections with WTU; (b) a letter from R.D. Ledbetter to Harry A.
Poth, dated June 23, 1972, relatina to the installation of the Quanah air switch and/)r the disconnection of TESCO's SWPS 69 kv emergency inter-connection.
(c) inspection of lines of any Texas electric utility on or near tne border of the State of Texas; (d) a memorandum from Dale Scarth to R.D.
Ledbetter, dated June 30, 1974, con-cerning the inspection of lines on or near the border of the State of Texas; (e) a letter from Louis Fikar to R.D.
Ledbetter, dated May 12, 1975, con-cerning the Childress air switch and/or an inspection of the controls at Vernon, Lake Pauline, Quanah, and Turkey, Texas. 368 277
- 5. All documents which relate or refer in any way, to:
(a) any electric cooperative's system; (b) any electric cooperative's system to determine if the electri: cooperative system was operating in interstate commerce.
- 6. All documents which relate or refer, in any way, to whether any Texas electric utility is or has operated in interstate commerce.
- 7. All documents which relate or refer to CP&L's interconnections into Mexico.
- 8. All documants which relate or refer, in any way to proposed or actual contracts and contract negotiations for wholesale power between Gate City Electric Cooperative, Gate City, Texas and WTU.
- 9. All documents which relate or refer, between TU and any other Texas electric utilities, in any way, to intercon-nections after the May 4, 1976 disconnection and prior to the Texas Public Utilities Commission's Docket 14 Order to reconnect.
368 278^
- e. -
Civil Subpoena To Testify
~
31uileb &.a.les of Amerita 8
NUCLEAR REGULATORY COMMISSION 2
Y In the nmtter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN 'ANTOhiO THE CITY OF AUSTIN and DOCKET NOS. 50-4 98 A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
, hand 2)
William Marquardt Texas Electric Service Company P.O.
Box 970 Fort Worth, Texas 76101 YOU AllE IIEllEIW COWANDED to appear T~
at noom....fl%..1.LQQ..C.9mnan..,SAr.nct..............
i n t he c i ty of....... D a,1,1,a, s, f,,, Tg x a, s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the... 2,@,t,h....duy of..... 6H S.V.V.t............19.2 3....a t.....NiD.9....o'c!ock A. M.
to testify in the alme entitled action (and thereafter from day to day, if necessary).
ItY OltDl;lt OF Ti!E ATOMIC sal'ETY AND I,1 CENSING llOAlti) in-Susan B.
Cyphert Ronald H.
Clark Act ornn (nr Antstennt Dar esitos t'noaed Statc e Ueenrtment of.Iustiee
...........................19......
whinuten.(o.c. 20530202)..2.24..64.72/6361 Telephene..
(202) 724-6616 368 2/9 10 C.V.lt. 2.720 (O presiding c(ficer or, if he is unnendable, the On onntion made prnmptis. esnd in n sv cuent Conneinninn mnv (1) nennah c.? modsfy the anb-at ur before the time specil'ed in'the subpoena poena if it in unreasonable or requires evidence for cumpliance b.% the person to wha *n the sub not relevant to any matter in insur, or (2) con-poena in titreeted, arnd on notice to the party at dition denial of the motion on just and reasonable schone irnslance the etshparna won issued, the terme.
d civil. SUHPOl;N A 'IV PRODt UK IM)CUMMNT OR OlWECT IInin9 tales af America l'
NUCLEAR REGULATORY COMMISSION 2
Y In the Inatter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS
- 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
1 and 2)
T.O William Marquardt Texas Electric Service Company P.O.
Box 970 Fort Worth, Texas 76101 Y0l! AllE ilEREHY COMMANDED to appear a t Room.... 8..C. 6.. /...1.1. 0. 0....C..o..m.. m..e..r..c..e... S..t..r..e..e..t....
in th e city of......C a 1,1 a s,,,, Tg pg,a s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.. 2,7,t,h.. day of.....A.V.9H.s.t.............19.. 7..!..n t....l.'.. 3,Q,,,n.clxk A. M.
to festify in the nlove entitled action and bring with you the document (s) or objecds) described in the attached schnlule. (and thereafter from day to day, if necessary).
ilY OltDI:H 01' TIIK ATO\\fic sal'ETY AND 1.frENS'NG HOAl'D HY Suean B. Cyphert Ronald H.
Cin*+
A ttornev (nr \\ ntstr.a t Dunn uns t'nated Statcn Ueonrtment af.Iuatiee
.......................I9........
\\\\anhonaton. U.C. 20530 Tricphone.4 2 '12.1.. 324n 6.432/6 3 61 (202) 724-6616 10 C.V.ll. 2.720 (n presidina ottirer nr. if he in unnenilable, the On motion made promptiv, nn l in non event Cnevnin nian mas e il qunnh or modsfy the n ul~
at or Icfore the time specelsed sn'the nufpnena poen't if it in s nreasonable or requiren evidence for compliance by the person to sthorn s'ne sub-not relevant to any matter i s innue, or (2) con.
poenn in thrected, and on notice to the party at dition dental of the motion on jrat and reasonable whose instance the subpcens~ wun issued, the t e rm s.
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all orig.inal (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, hcwever produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Wheeling" means the transportation of electricity by a utility over its lines for another utility; also includes the receipt from and delivery to another system of like amounts but not necessarily the same energy.
- 3. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
- 4. "WTU" means West Texas Utilities Company.
- 5. "TESCO" means Texas Electric Service Company.
368 281
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered censecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
Should any questions arise concerning this subpoena, please contact Susan B.
Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Department of Justice P.O.
Box 14141 Washington, D.C.
20044 368 282
DOCUMENTS TO LE PRODUCED
- 1. All documents which relate or refer, in any way, to:
(a) proposed or actual contracts and contract negotiations for wholesale power between Gate City Electric Cooperative, Gate City, Texas and WTU; (b) a telephone communication between William Marquardt and Durwood Chalker on June 17, 1975; (c) the information William MarquarJt re-ceived on June 12, 1975, conct rning Articles 7 and 8 of the pragosed November 21, 1974 Gate City Electric Cooperative, Gate City, Texas and WTU contract; (d) all communications concerning proposed or actual contracts and contract negoti-ations for wholesale power between Gate City Electric Cooperative, Gate City, Texas and WTU.
- 2. All documents which relate or refer, in any way, to:
(a) Western Farmers Electric Cooperative; (b) proposed and actual interconnections between Western Farmers Electric Cooperative and Brazos Electric Power Cooperative, Incorporated.
- 3. All documents which relate or refer, in any way, to wheeling power to or for any Texas electric utility.
- 4. All documents which relate or refer, in any way, to:
(a) the City of Seymour, Texas; 368 283
1 (b) requests for power made by the City of Seymour, Texas to TESCO.
- 5. All documents which relate or refer, in any way, to the inspection of lines of any Texas electric utility on or near the border of Texas.
- 6. All documents which relate or refer, in any way, to interconnections between TU and any other Texas electric utility after the May 4, 1976 disconnection and prior to the Texas Public Utilities Commission's Docket 14 Order to reconnect.
368 284
Civil Suppoena To Testify hineb Bl.alca of Amerita NUCLEAR REGULATORY COMMISSION A
Y In the mniter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS 50-4 9B A CENTRAL POUER AND LIGHT COMPANY j,
50-499A (South Texas Project, Units Nos.
and 2)
)
D.
E.
Simmons Houston Lighting and Power Company P.O.
Box 1700 Houston, Texas 77001
-YOU ARE llEREBY COMMANDED to appear a t Roo m.. 1. 2. 0.. 0. 0..,... 5. 1 5....R..u..s..k.....................................
in the cit
!! o.u,s t,9,n,,,,, T,e x a, s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the... 5or...................ilu y o f.....S..e..p t..e..m..b..e..r.......
2th A.
to testify in the aluwe entitled action (and thereafter from day to daf, if necessary).
IW OltDMit 01* Ti!E ATOMIC SAFETY AND 1.! CENSING ltOAl(D in' Susan B.
Cyphert Ronald H.
Clark A ttorner (nr \\ ntstrosa t Dis ision o
l'n u ted.%taten Department of.lustice
.* s E O....* *
. Ranhinston, D.('. 205:30 rel. phone..(202.).. 22.4..6422/6 3 61 (202) 724-6616 368 283 10 C.V.lt. 2.720 (n presiding officer or if he in unnvailable, the On on stion snade promptl\\, nnd in nous event lomminnian mnv til qunnh or modtfy the nub-at or before the time spe cified sn'the subpoena poena if it is unreasonable or requires evidence c
for comple'ar:~
%' the person to ethorn the setb=
not relevant to any matter in in sur, or (21 con.
pornet ie
- nd on nnlite to the party at dition denial of Ik motion on just and reasonable tehnn a* sn..
.hpo.*na sLtan in stned, the terms.
e CIVII. SUHPOMN A TO PROlH CM IOCUMENT OR OtuECT Ltileb 91.a,les of Amerita NUCLEAR REGULATORY COMMISSION 2
y in the rnatter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and IXI('.Ki.T NOS
- 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
{gand 2)
D.
E.
Simmons Houston Lighting and Power Company P.. O. Box 1700 Houston, Texas 77001 YOU AllE IIEltEHY COMMANDED to appent a t Roo m...1. 2. 0. 0. 0.. t... 5.1. 5....R..u..s.. k.......................
i n th e c i ty o f.......!.19.H s t, gg,,,, T,e,x a s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.....N.b.. day of...b3.8.te,@,e.5........19.. 2 9..at....N.iM....o' clock A.M.
to festify in the alwwe entitled action and bring with you the document (s) or object (s) tiescrilcl in the n'tached schnlule. (and thereafter from day to day, if necessary).
IlY ORDHH OF Tile ATOYlC SAFETY AND I.trKNSING llOARD HY Susan B. Cyphert Ronald H.
Clark Allarnet for A r.lutrone t Unt in tort I'noeed SIatc e Uepnrtment af.Iuaauee
........................,19.......
ua mhinuton. D.C. 20530 Telet. hone..(2.02).. 72.4n6 432/6 3 61 (202) 724-6616 3.68 286 10 C.V.lt. 2.720 (n presirlina ottirer or, if he in unnvailable. al e On motion maule promptls, nnel in non event Comminnir.n may fil qunnh or modify the sub.
at tot in' fore the time specified en'th. pubporna poenn if it in unreantmable or requiren evidence for compliance by the person to uham the sub.
not relen ant to any matter in innue, or (2) con.
poenn in siirertcul, aryl or' nnlice in tho' party at dition denial of the molinn on just and reasonable
' whn?e instance the subpos'na wan issued, the terms.
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all 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 con-ference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and testa, reviews, contracts, agreements, pamphlets, diaries, calendar or diary entries, mapt
- graphs, charts, statistical records, computer data or paper similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one con be used by the other.
3.
" Economy energy" Reans energy produced and supplied from a more economical source, substituted for energy that could have been produced by a less economical source.
4.
"Whealing" means transportation of electricity by a utility over its lines for another utility; also includes the receipt f r om and delivery to another system of like amounts but not necessarily the same energy.
- 5. "HL&P" means Houston Lighting & Power Company.
- 6. "GSU" means Gulf States Utilities Company.
- 7. "FPC" means Federal Power Commission.
8.
" Austin" means City of Austin.
10.
" CPS" means City Public Service Board of San Antonio.
368 287
- 11. "TMPA" means Texas Municipal Power Agency.
- 12. "Brazos" means Brazos Electric Power Cooperative, Inc.
- 13. "STEC" means South Texas Electric Cooperative, Inc.
- 14. "DP&L" means Dallas Power & Light Company.
- 15. "TESCO" means Texas Electric Service Company.
- 36. 'LCRA" means Lower Colorado River Authority.
- 17. "CP&L" means Central Power & Light Company.
- 18. "TP&L" means Texas Power and Light Company.
- 19. "WTU" means West Texas Utilities Company.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped cording to the individual paragraph of the subpoena tion to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
368 283
.. _ ~..
8 In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents eacn page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to t
~ompany.
e Should
-j quections arise concerning this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Department of Justice P.O.
Box 14141 Washington, D.C.
20044 DOCUMENTS TO BE PRODUCED
- 1. All documents which relate or refer, in any way, to proposed or actual contracts and contract negotiations for wholesale power between Gate City Electric Cooperative, Gate City, Texas, and WTU.
- 2. All documents which relate or refer, in any way, to:
(a) GSU interconnections, and communications concern-ing interconnections, with HL&P; (b) the Huffman interconnection between GSU and HL&P; (c) a letter from T.H. Wharton to the 'PC dated May 1, 1958, concerning a report on the operation of the Huffman interconnection; (d) the FPC report on " Power Interruption, Gulf States Utility Company System, May ll, 1967";
(e) the upgrading of the Huffman interconnection.
- 3. All documents which relate or refer, in any way, to:
(a) all requests by any electric utility to participate in any generation project with HL&P; 368 289 f
(b) all requests by GSU to participate in a lignite or coal generation unit with HL&P; (c) participation by GSU in the Allens Creek nuclear project.
- 4. All documents which relate or refer, in any way, to:
(a) HL&P's projected load growth from 1980 through 19a4-(b) HL&P's projected generation capacity for the years 1980 through 1988; (c) HL&P's projected reserves for the years 1980 through 1988;
- 5. All documents which relate or refer, in any way, to:
(a) EL&P's contracts and contract negotiations pertain-irg to the purchase of any type of power from any o?her electric utility; (b) HL&P's contracts and contract negotiations with Austin pertaining to the purchase of power from Austin; (c) any communication with R.L.
Hancock or Richard Balough of Austin concerning the intrastate only restrictions contained in its contracts with HL&P and TU; (d) any communication with CPS regarding the purchase of any type of power by HL&P from CPS; (e) any communication with TMPA or its representatives regarding the purchase of any type of power from the TMPA Gibbons Creek project once it is completed; (f) any communication with Brazos or STEC regarding the purchase of power from the San Miguel project by HL&P.
- 6. All documents which relate or refer, in any way, to economy power transactions.
368 290
- 7. All documents which relate or refer, in any way, to the Florida power brokerage arrangement which HL&P is or has been investigating.
- 8. All documents which relate or refer, in any way, to the wheeling of electric power.
- 9. All documents which relate or refer, in any way, to HL&P's fuel contracts.
- 10. All documents which relate or refer, in any way, to:
(a) the May 4, 1976 disconnection by HL&P from all other electric utilities within the state of Texas; (b) the closing of ties between HL&P and TU, TP&L, DP&L, and TESCO; (c) a letter from J.G.
Reese to Charles Herring of LCRA, Hulsey of TU, Wayne Siegelin of CP&L, J.K.
Spruce of CPS, and Dan Davidson of Austin concern-ing the May 4, 1976 opening of interconnections by HL&P with other electric utilities in Texas; (d) a letter from D.E.
Simmons dated May 5, 1976 to Soderberg of LCRA, Dan Davidson of Austin, G.R.
Coffman of TP&L, Wayne Siegelin of CP&L, and Jesse Poston of CPS concerning emergency interconnections; (e) requests by CP&L, WTU, LCRA, Austin, and CPS, made to HL&P and TU, after the May 4, 1976 opening of interconnections by HL&P and TU, to have HL&P and TU close their interconnections,
- 11. All documents which relate or refer, in any way, to inspections made by TD, TP&L, TESCO, DP&L, and HL&P to deter-mine if an electric utility in the state of Texas is or had been in interstate commerce.
- 12. All documents which relate or refer, in any way, to actual or contemplated negotiations between the City of Houston, Texas, acting through and by its Department of Public Service and Utilities Coordinator, and GSU pertaining to the granting of a franchise, or other contractual agree-ment, to GSU for the furnishing of electrical service within the boundaries of the City of Houston.
- 13. All documents which relate or refer, in any way, to the Public Utility Regulatory Policies Act of 1978.
368 291
-s_
Civil Subpoena To Testify llttileb Bh.t,,les of Atiterita NUCLEAR REGULATORY COMMISSION 3
Y In the runtter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN )NTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2)
)
Art Wilson City Public Service Board of San Antonio P.O.
Box 1771-145 Navarro Street
' San Antonio, Texas 78296 YOU ARE ilEREHY COMMANDED to alvear
~~~~~~ ~
at Room...f!:.U.t...R5.5,,,E,:,,,D,u,r,a,ng,9,,,B,,Ql,d,,,,,,,,,,,,,,
......................g.......g.............g...........................................................
in the city or.................g on the.. 7.5.t.h....duy of.....Ef?P.t RGhf K......19.2S....at....NiRR....o' clock A.M.
to testify in the alove entitled action (and thereafter from day to day, if necessary).
ItY Oltill.'t Ol' Tile NIUMIC sal'ETY AND t.lCENSING llOAltl)
I!Y Susan B.
Cyphert Ronald H. Clark ot atorne% [nr,\\ ntatrus t Dives in,nn,n ed s,m. o m.,,,,e n, or..e,1<,
............................9.......
. n ashington.(D.C. 20$30202.)..224. 642.2/6361 Tclephone..
(202) 724-6616 368 292 10 C.V.it. 2.720 tu presidina officer or if he in unnendnide. the On motion made promptiv. and ior arry event Comminnion may til qunnh or modify the nub-at or before the time epecified in'the subpoena roena if it is osnreasonable or requires evidence for compliarlee b), the person to schone the sub-not reletant to any matter in issue, or tti con.
po*na is riirected, artd on notice to the party at dition denial cf the motion on just and reasonable schose instance the subpnenn scan issued, the te rm s.
-e civil. SUliPOEN A TO PitODI CE DOCUW.NT d Ol1 JECT hileb staica of Amerita p
NUCLEAR REGULATORY COMMISSION 2
y in the matter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS
- 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2)
O Ar t-Wilson City Public Service Board of San Antonio P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU ARE ilEREBY COMMANi>"n to em> car a t Rootn.............G....1. 3..,... 6. 6 5... E.
'.D..u..r..a..n. 9.o....B..l..v.. d.
the c.ty of..........S an An ton..io,
Te
..............................xas..................................................
in i
on the. 7d th..... day of....SRPACQDCI.......19.. 7.9..at.....Ri.ne...o' clock A. M.
to testify in the alxwe entitled action and bring with vou the document (s) or object (s) described in the attached schedule. (and thereaf ter from day to day, if necessary).
llY ORDI:lt OF Tile ATOMIC SAFETY AND I,trENSING llOAHD llY Susan B. Cyphert Ronald H.
clark A ttorney (nr Anturren t Dir in non l'n eied.%Iatcn Uepnrtment o(.Iteniire
...........................I0.......
isanhington. D.C. 20530 Telephone./,2.021.. 724=6.472/6 3 61 (202) 724-6616 368 293 10 C.V.fl. 2.720 (()
presidina ollicer nr. if he in unneniinkle, the On onntion unnde prnmptis, nnri in nns et ent Comuninnian mnv til nunnh or morltfy the sul-of nr ln'[nte the time up.'etlied in'th
- snFporno poenn if it in untrannnable or requiren cridence for complinnre by, the prtenn in ethorn the nub =
not relet ant to any matter in in nter, or (21 con.
poena in directed. arsd n.' notice to the party at dition denial of the motion nn just and reasonable schone instance the subpnena swa issued, the serm e.
f SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all 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 con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
- 4. "TP&L" means Texas Power and Light Company.
- 5. "DP&L" means Dallas Power & Light Company.
6.
"TESCO" means Texas Electric Service Compar.y.
7.
"HL&P" means Houston Lighting & Power Company.
- 8. " CPS" means the City Public Service Board of San Antonio.
9.
"WTU" means West Texas Utilities Company.
368 274
f
- 12. "STEC" means South Texas Electric Cooperative, Inc.
- 13. "Medina" means Medina Electric Cooperative, Inc.
- 14. "Brazos" means Brazos Electric Power Cooperative, Inc.
- 15. "PTI Study" means the Power Technologies, Inc. study entitled, " Multi-Area Reliability Study of ERCOT and SWPP for the Central and Southwest Corporation".
- 16. "CSW" means Central and Southwet t Corporation.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of orivilege, furnish a list which identifies each document fe which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individaal paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
368 295 T
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
Should any questions arise concerning this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Department cf Justice P.O. Box 14141 Washington, D.C.
20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to:
(a) efforts by CPS to have TU, TP&L, DP&L, TESCO and HL&P close their interconnections with CPS; (b) the effect of the closing of these ties upon the City of Hondo, STEC, Medina, CP&L, WTU, and any other utility system in Texas if CPS would have had to open its ties with these systems to obtain reconnections.
3.
All documents which relate or refer, in any way, to:
(a) CPS's projected loads for 1980-1985; 368 296
_3_
(b) CPS's projected generation capacity for 1980-1985; (c) CPS's projected reserves for the 1980-1985; (d) any requests by or contracts with an electric power system to purchase power from CPS.
4.
All documents which relate or refer, in any way, to CPS's fuel contracts or any fuel contracts that are presently being negotiated.
5.
All documents which relate or refer, in any way, to any rate comparison studies that have been done.
6.
All documents which relate or refer, in any way, to Texas Public Utilities Commission Docket 14.
7.
All documents which relate or refer, in any way, to the San Miguel plant and the transmission system Brazos is building to transmit power from San Miguel to the Brazos load centers.
8.
All documents which relate or refer, in any wey, to the 1976 San Antonio Blackout.
9.
All documents which relate or refer, in any way, to:
(a) the PTI 6:udy that was done for CSW; (b) a memorandum entitled "Effect on CPS of Recent Central & Southwest Corporation Activities" dated March 1, 1976.
368 297 Civil Subpoena To Testify
%tilch Bf. ales of Anterita p
NUCLEAR REGULATORY COMMISSION A
T in the inntier of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
)and 2)
J.
K.
Spruce City Public Service Board of San Antonio P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU ARE HEREBY COMMANDED to appear at noom..t.U.r.. 6. 6,,5,,,E,:,,,p,g,a,ng,9,,,B,,Q,d,,,,,,,,,,,,,,,
i n t he c i ty o f......S.a,n,,,A n t gn i,o, f,,, Tg,x a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the... 2,,5,,t.D.,. day of.... SSP.t,g_mbe,r.......19.2.9....at.. 9n.9........o' clock P. M.
to testify in the aluwe entitled action (and thereafter from day to dayr if necessary).
ilY OttDMit 01' TliK ATOMIC SAFETY AND l.ICF.NSING llOAltD itY Susan B. Cyphert Ronald H.
Clark Altnr.rev for A nlatrus t Dis in son t'nited Ntatc= Ueonrtment af.Iustice
...........................\\9.......
. nashinstton,(D.C. 20530 202.)..224. 6422/6361 re t< phone..
(202) 724-6616 368 298 10 C.V.R. 2.720 (n presidine officer or. if he in unnenilnble, the on motion made promptis, und un n sv crent Comminnion mny til nunnh or mndify the anh at or before the time specified sn'the subparnc poena if it is sonreasonable or requires evidence for comptinnee by; the person to erha*n the sub=
not relevant to any matter in innue, or (21 con
- poena is directed, and on notier to the party at dition denial of the motion on just and reasonable whane instance the subpnena avun issued, *he term s.
a civil. SUHPOEN A TO PROOt CM IMICUMENT OR OlkIECT hileb Bt.gles of America NUCLEAR REGULATORY COMMISSION 2
Y In the tnatter of:
HOUSTON LIGHTING & POWER COMPANY
~
THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOC'.KMT N(E
- 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos, and 2)
~0 J.
K.
Spruce C;.ty Public Service Boaru of San Antonio P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU AllE IIEREBY COWANDED to aplear a t aoo m.. t.U. c.. 6,6, ),,,,E,:,,,D,m,ng,9,,,B,,1, v,d,3,,,,,,,,,,,,,,
i n th e c i ty o r......... !.a,p,,,A,n t,g,9,i,9, f,,, Te,y,a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the... 2,4,t.h...duy of......S.RP.t.9.@nX.....19.. 7.2..at.. 9.t.LS......o' clock A. M.
to festify in the a!xwe entitled action nnd tring with you the document (s) or object (s) described in the attached schedule. (and thereafter from day to day, if necessary).
uv Onnna 01' TiiM ATOstlC sai'ETY AND I.1CINSING llOAl(D In*
Susan B. Cyphert Ronald H.
clark Arnornes (nr Ant, trust Useinicus l'nited Staten Department of.lustsee
- """"""*"""""}g*""*
u a nhinseton, D.C. 20530
~f relechnec./,2.02.).. 72.4n6.472/6 3 61 Jbb 29Q' (202) 724-6616 10 C.V.it. 2.720 (f) presidine nitiver or,.[ he in unavniinhle, the On matinn made pre.mplis, nnd in nov co ent Comminninn mnv IU qunnh or modrfy the sub-at tar lovfore the Isme spe'enf ord in'the suFporna poents if it in unreannnable or reye;iren evidence
[Dr Complinner by the person to whom the sule not relCVant to any Matter in insur, or (2) Cone roenn in clircried, artd on notice in the party at dition denial of the motion an just and reasonable whose ir' stance the subpoe'nn wan issued, the
- terme,
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all original (or copies where originals are unavailable) and non-identical copies (whether different from criginals by reason of notation made on Euch copies or otherwise) of all written, recoraed or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, t c ? ': g r a m s, notes or sound recordings of any type of conversation, meeting or con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
- 4. "TP&L" means Texas Power and Light Company.
- 5. "DP&L" means Dallas Power & Light Company.
- 6. "TESCO" means Texas Electric Service Company.
7.
"HL&P" means Houston Lighting & Power Corapany.
- 8. " CPS" means the City Public Service Board of San Antonio.
9.
"WTU" means West Texas Utilities Company.
368 300
s
- 11. "LCRA" means Lower Colorado River Authority.
- 12. "STEC" means South Texas Electric Cooperative, Inc.
- 13. "Medina" means Medina Electric Cooperative, Inc.
- 14. "Brazos" means Brazos Electric Power Cooperative, Inc.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, cubject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
IN'iTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
Thic procedure, if followed, will preserve the identity cf all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company. 368 301
Should any questions arise concerning this subpoena, please contact Susan B.
Cyphert (202-724-6472 or 724-6361) or Ronald H.
Clark (202-724-6616) at the following address:
Department of Justice P.O. Box 14141 Washington, D.C.
20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO; and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to:
(a) efforts by CPS to have TU, TP&L, DP&L, TESCO and HL&P close their interconnections with CPS; (b) the effect of the closing of these ties uprn the City of Hondo, STEC, Medina, CP&L, WTU, and any other utility system in Texas if CPS would have had to open its ties with these systems to obtain reconnections.
3-All documents which relate or refer, in any way, to:
(a) CPS's projected loads for 1980-1985; (b) CPS's projected generation capacity for 1980-1985; (c) CPS's projected reserves for 1980-1985; (d) any requests by or contracts with an electric power system to purchase power from CPS.
4.
All documents which relate or refer, in any way, to CPS's fuel contracts or any fuel contracts that are presently being negotiated.
368 302
_3_
/
5.
All documents which relate or refer, in any way, to any rate comparison studies that have been done.
6.
All documents which relace or refer, in any way, to Texas Public Utilities Commission Docket 14.
7.
All documents which relate or refer, in any way, to the San Migual plant and the transmission system Brazos is building to transmit power from San Miguel to the Brazos load centers.
8.
All documents which relate or refer, in any wa_.
'. o the 1976 San Antonio Blackout.
9.
All documents which relate or refer, in any way, to instances of competition with any other Texas electric utility.
368 303 Civil Subpoena To Testify n_
Thineb Eaten of Amerita p
NUCLEAR REGULATORY COMMISSION v
in the nmtier of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 98A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
ygand 2)
Robert Mecke City Public Service Board of San Antonio P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU ARE ilERERY COMMANDED to appear
- _T
~~
a t noom....G,,1,b,,,6,5,5,,, L,, D u,r,g g g,o,,,B,1,y,d,,.,,,,,,,,,,,,,
......................g.......g...;.g..g.....g...g......................................................
inthecityor................................................................................................
on the... 2,Q,t,h,,,,,luy of......fP.9.9.t#m!PM.....19.2.9....a t...N.i. nc......o' clock A. M.
to testify in the alove entitled action (and thereaf ter from day to day, if necessary).
ilY ORDUlt OF Tile ATOMIC SAFETY AND 1.1 CENSING HOAHD IfY Susan B. Cyphert Ronald H.
Clark Ant ornes for Antstrosat Dwintron n nised statea Department of.lussice
~~~~~~~~~~"~"39~**"
wu.n...:,n. o.c. 20s30 Tctephnne..i2 2.).. 2.24-.64.72/6 3 61 (202) 724-6616 10 C.V.it. 2.720 (0 presidine ollicer or, if he in wrnt'aila!de. the On unntion unade promptis, ranal in n.rv es cnt Commtanian mav **I quanh or moduly the nub-at or before the time spe'rtlied in'the subpoena poena if it is unreasanoble or requures evidence for compliance by the person to schom the sub.
not relet ant to any matter in innue, or 42D con.
'soenn is eliverled, and on notice to the party at dition denial of the motion on just and reasonable tehnse instance the sulopnena uun inet.ed, the terme.
e CIVII. SUHPOEN A To PRODI CK IMWUMENT OR OlWECT 31nileb &a,1les of America NUCLEAR REGULATORY COMMISSION 2
Y In the rnatter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKMT NOS. 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2) 0 Robert Mecke City Public Service Board of San Antonio P.O. Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU ARE HEREHY COMMANDED to appear a t Roo m.....G... 1. 3..,... 6. 6. 5....E......D..u..r..a..n. 9. o....B..l..v..d..
in th e c i ty of......S,a,n,, A,n,t,g,i g f,,,,Tg,x a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,..
on the... 2.4.tIA..duy of......S.@ I.CR@.CI.....19.. 7.R..at..... 9. A 3.0...o' clock A. M.
to testify in the alme entitled action nnd bring with you the document (s) or object (s) described in the attached schedule. (and thereafter from day to day, if necessary).
llY ORDHit 01' TilM ATOMIC sal'ETY ANI.
'Ci NSING HOAl(D ln-Susan B. Cyphert Ronald H.
Clark Altarnev fnr Antitreest Division i*nited.'ltatcn DepnrIment of.Iuatire
..........................I9.......
\\ta hington. D.C. 20S30 relephone..(2.02.).. 72.4n6.472/6 3 61 (202) 724-6616 36g
}
10 C.V.lt. 2.720 in presiding ottirer or, it he in wenvailabic, the On onntuan made promptl\\, nn't in norv curent Ctmmin nion mnv til quanh or motlify the n osh-at tst befort the time op.*ctlied in t re subpoena poena if it in tanreanonable or requiren et idence
~ i for compliance b_\\; the person to erho*n the sedw not relet ~nt to any matter in innue, or 121 con.
poena in dircried, and on notice to tire party at dition denini of the motion on just and reasonatde
' u hnne instaner the subpnenn guan issued, the terms.
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, Pithout limiting the generality of its meaning
- .1 originci (or copies where orig',als are unavailable) and non-identical copies (whet:ter
'. f e r e n t from originals by reason of notation made on such :opies or otherwise) of all written, recorded or graphic matter, however produced or reproduced,.hether or not now in existence, of correspondence, telagrams, notes or sound recordings of any type of conver ation, mieting or con-ference, minutes of directors' r committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar tc any of the foregoing, however denominated, including preliminary version 3 drafts or revisions of any of the foregoing and any supp ting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
4.
"TP&L" means Texas Power and Light Company.
5.
"DP&L" means Dallas Power & Light Company.
- 6. "TESC0" means Texas Electric Service Company.
- 7. "HL&P" means Houston Lighting & Power Company.
- 8. " CPS" means the City Public Service Board or' San Antonio.
9.
"WTU" means West Texas Utilities Company.
368 30g
- 11. "LCRA" means Lower Colorado River Authority.
- 12. "STEC" means South Texas Electrac Cooperative, Inc.
- 13. "Medina" means Medina Electric Cooperative, Inc.
- 14. "Brazos" means Brazos Electric Power Cooperative, Inc.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of p 'rilege, furnish a list which identiffus each document for inich privilege is claimed and wh.ch includes the following information for each such document: date, subject matter, sencer, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
368 307 Should any questions arise concerning this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the iollowing address:
Department of Justice P.O. Box 14141 Washingtor., D.C.
20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to:
(a) efforts by CPS to have TU, TP&L, DP&L, TESCO and HL&P close their interconnections with CPS; (b) the effect of the closing of these ties upon the City of Hondo, STEC, Medina, CP&L, WTU, and any other utility system in Texas If CPS would have had to open its ties with these systems to obtain reconnections.
3.
All documents which relate or refer, in any way, to:
(a) CPS's projected loads for 1980-1935; (b) CPS's projected generation capacity for 1980-1985; (c) CPS's projected reserves for 1980-1985; (d) any requests by or contracts with an electric power system to parchase power from CPE.
4.
All documents which relate or refer, in any way, to CPS's fuel contracts or any fuel contracts that are presently being negotiated.
368 308 5.
All documents which relate or refer, in any way, to any rate comparison studies that have been done.
6.
All documents which relate or refer, in any way, to Texas Public Utilities Commission Docket 14.
7.
All documents which relate or refer, in any way, to the San Miguel plant and the transmission system Brazos is building to transmit power from San Miguel to the Brazos load centers.
8.
All documents which relate or refer, in any way, to the 1976 San Antonio Blackout.
368 309...
t Civil Subcoena To Testify
~
Liibb Bl.aha of America p
NUCLEAR REGULATORY COMMI.9SION 1
w in the nir.tter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN AITONIO THE CITY OF AUSTIN and DOCKET NOS. 50-4 9 8 A CENTRAL POWER Ab"1 LIGHT COMPANY 50-499A (South Texas Proj6ct, Units Nos.
1 and 2)
TO F.
W.
2ayett City Public Service Board of San Antonio P.O.
Box 1771 145 Navarro Street San Anton.10, Texas 78296 YOU ARC ilEREHY COMMANDED to ammar at Room...G...1. 3..,... 6. 6. 5....E......D..u. r..a..n. 3.o....d..l..v..d..
i n t he c. ty o f....S..a..n.... A...n..t..o..n.. i..o...,....T..e..x..a.. s..............................................
i on the...U t)l....da y of.....S.9.P.t. 91@.9J....... 19. 2.9....a t......H A D.9...o'cl oc k A. M.
to testify in the alme entitled action (and thereafter from day to day, if necessary).
fly OllDI;tt Ol' Till; ATOMIC SAFETY AND t.ICENSING llOAl(D in-Susan B.
Cyphert Ronald H.
Clark A tt. senn (nr,\\ ntstresn: Uwin ton
......................>.,19........
l'n uted State n Department of.lus*i:e bt ashanuton,'D.C. 20$30 Tclerhone.. 202)..2.24:.64.7.2/6361 (202) 724-6616 368 310 10 C.V.it. 2.720 (D presidine oflicer or, il ne is unnendnhie t're On onntion onarle prompris, nn l in n tv crent Comminninn may ill qunnh or modufy the avb.
at or before the time specified sn'the sulpoena poena if it is sunreasonable or requires evidence for compliance b,%, the person to achn>n the sub*
not relevant to any matter in innue, or (2) con.
poenn is directr 1, orgd on notice to the party of dition denial of the motion on j sst and reasonable schose instance the enhpo.*na was is sued. th.
terme.
civil. SUHPOEN A 'IT) Pitopt CE IX)CUMENT OR OluECT hinileb Bl. ales of Amerita
~
v NUCLEAR REGULATORY COMMISSION 1
Y in the rnatter of:
HOUSTON LIGHTING & POWER COMPANY
~
THE CITY OF SA.N ANTONIO THE CITY OF AUSTIN and DOCKET NOS
- 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2)
O F.
W.
Payett City Public Service Board of San Antoniv P.O.
Box 1771 145 Navarro Street San Antonio, Texas 78296 YOU AltE ilEltEHY COMMANDED to appear at oom.....G... 1. 3.. t... 6. 6. 5....E.....D...u..r..a..n..g..o... B..l..v..d..
-i n t h e e ty o f.........S..a..n.... A..n. t..o..n. i.o...,....T..e..x..a...s...........................................
i on the. 2,,4.D.....duy of... 992.t,e,@S.T.......19.. 7.2..at..... 9.I.4.5,,,g. clock A. M.
to testify in the aluwe entitled action and bring with you the document (s) or object (s) described in the attached scholule. (and thereafter from day to day, if necessary).
ilY Olif)t;it OF Tile ATO\\ tlc sal'ETY AND I,1 CENSING llOAl(D HY Susan B. Cyphert Ronald H.
Clark A ttusrney (nr A nistr4* t Utt in ton t 'ntled.% tate
- Department of.lus tice
........ 19.....
\\tashinton. D.f'. 20530 Tetechnne..(2.02.).. 72.4 6 472/6 3 61 (202) 724-6616 368 311 10 C.Y.lt. 2.720 tn presidina articer nr. it he i. unm niinble. the On anotion made promptir. rund in n tv crent C.mmission mnv til quash or modofy the nuh-at or t -' fore the time specified in'the sulpoena poenn if it is unreannnable or requiren evidence for complinnee by, the person to who n the sub.
not relen ant to any matter in in n ue, or I2) con.
poena in riirected. and on notice in the party at dition denini of the motion on just and reasonable schone instance the subpnenn was innued, the terme.
-- ~-- w.w m _-
.a.m
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all original (or copies where originals are unavailable) and non-identica) 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 con-ference, 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, agreements, pamphlets, dimries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the fotegoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
- 4. "TP&L" means Texas Power and Light Company.
5.
"DP&L" mr:ans Dallas Power & Light Company.
6.
"TESCO" means Texas Electric Service Company.
7.
-HL&P" means Houston Lighting & Power Company.
8.
" CPS" means the City Public Service Board of San Antonio.
- 9. "WTU" means West Texas Utilities Company.
368 312
- 11. "LCRA" means Lower Colorado River Authority.
- 12. "STEC" means South Texas Electric Cooperative, Inc.
- 13. "Medina" means Medina Electric Cooperative, Inc.
- 14. "Brazos" means Brazos Electric Power Cooperative, Inc.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents respondc.
III.
INSTRUCTIONS REGARDING GROUPING
_ AND NUMBERING DOCUMENTS It is reqJested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents woula be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followe(
will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
368 313 Should any questions arise concerning thir subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Department of Justice P.O.
Box 14141 Washington, D.C.
20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HLSP with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to:
(a) efforts by CPS to have TU, TP&L, DP&L, TESCO and HL&P close their interconr.ections with CPS; (b) the effect of the closing of these ties upon the City of Hondo, STEC, Medina, CP&L, WTU, and any other utility system in Texas if CPS would have had to open its ties with these systems to obtain reconnections.
3.
All documents which relate or refer, in any way, to:
(a) CPS's projected loads for 1980-1985; (b) CPS's projected generation capacity for 1980-1985; (c) CPS's projected reserves for 1980-1985; (d) any requests by or contra;ts with an electric power system to purchase power from CPS.
4.
All documents which relate or refer, in any way, to CPS's fuel contracts or any fuel contracts that are presently being negotiated. 368 314
5.
All documents which relate or refer, in any way, to any rate comparison studies that have been done.
6.
All documents which relate or refer, in any way, to Texas Public Utilities Commission D0cket 14.
7.
All documents which relate or refer, in any way, to the San Miguel plant and the transmission system Brazos is builuing to transmit power from San Miguel to the Brazos load centers.
8.
All documents which relate or refer, in any way, to the 1976 San Antonio Blackout.
368 315 civil. SUHPOEN A TO PROlH CM IMWUMENT OH OluECT
~
?Jinineh E.ates of America p
NUCLEAR FIGULATORY COMMISSION 1
1 in the runttur of:
HOUSTON LIGHTING & POWER COMPANY TH c. CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOC'KF'T NOS
- 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
}gand 2)
Charles Herring Lower Colorado River Authority P.O.
Box 220 Austin, Texas 78767 YOU AltE IIEltEHY COMMANDED to appear a t noom.... 7.5,2,,,,,,3,Q,Q,,,E,a,s, t,, 8,t,h,,,S, t re e,t,,,,,,,,,,,,,,,,
i n t h e c i ty of................ A.. u..s. t..i..n.. /....T..e..x..a..s...................................................
on the.....'i.t.h.....duy of..... 9.9.t.@R.r.........19.. 7.R..at....E,1,g yg,n.o' clock A. M.
to testify in the alxwe entitled action and bring with you the document (s) or object (s) describal in the attached schedule. (and thereafter from day to day, if necessary).
IlY Oi!DElt 01 Tile ATOMIC SAFETY AND !.tCENSING llOAHD llY Susan B. Cyphert p nald H.
Clark s ou.rnes inr A ntstrn<t novin uun
'"""'"*""""""'39" l'n riec' St ate n Derpartircent of.lus tice
\\\\ashington, D.C. 20530 Telet hone..(2.02.1.. 724n 6472 /6 3 61 (202) 724-6616
}fQ
}jf 10 C.V.lt. 2.720 (n presidina offirer nr. if he in unavailable. the On onnlinn made prompris. tsnd in norr cr.ent Comminninn mav til quash or modofy the sub-at or l#[ ore the time spectlied in'th. nul' par'no poenn if it in urerranonable or requiren evidence for comp.;nnte b.x the person to echarn the sub.
not re!ct ant to any matter in innue, or (2) con.
puerut in elirected, and on notlcr to the party at dition denial of the mto! inn on just and reasonable
' u hnse instance the subpne. wan is sued, the te rm s.
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all original (or copies where originals are u1available) 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 con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any st.pporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
4.
"TP&L" means Texas Power and Li ht Company.
3 5.
"DP&L" means Dallas Power & Light Company.
- 6. "TESCO" means Texas Electric Service Comnany.
7.
"HL&P" means Houston Lighting & Power Company.
- 8. " CPS" means the City Public Service Board of San Antonio.
9.
"CP&L" means Central Power and Light Company.
368 317
- 10. "WTU" means West Texas Utilities Ccmpany.
- 12. "LCRA" means Lower Colorado River Authority.
- 13. "TPUC" means The Public Utility Ccmmission of Texas.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronologic=1 order.
In order to facilitate the handling of the documents which vill be received it would be appreciat d if each of the documents would be numbered consecutively.
It is suggested that in numbering the documen'es each page be numbered, except in those instances where the documents are baund together, when numbering enly the first page is appropriate.
This procedure, if followed, will preserve the identity of cll the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
368 318 Should any questions arise concerning this subpoena, please contact Susan B. Cyphert (202-724-6e_72 or 724-636])
or Ronald H. Clark (202-724-6616) at the following address:
Department of Justice P.O.
Box 14141 Washington, D.C. 20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relace or refer, in any way, to efforts by LCRA to have TU, TP&L, DP&L, TESCO, and HL&P close their interconnections with LCRA.
3.
All documents which relate or refer, in any way, to TU, TP&L, DP&L, TESCO, and HL&P's response to LCRA regard-ing LCRA's request for the closing of interconnections before May 2, 1977.
4.
All documents which relate or refer, in any way, to:
(a) LCRA's projected loads for 1980-1985; (b) LCRA's projected generation capacity for 1980-1485; (c) LCRA's projected load for 1980-1985; (d) any requests by or contracts with an electric power system to purchase any type of power from LCRA.
5.
All documents which relate or refer, in any way, to LCRA's fuel contracts or any fuel contracts that are pre-sently being negotiated.
6.
All documents which relate or refer, in any way, to any electric rate comparison studies.
368 3t9 7.
All documents which relate or refer, in any way, to transmittal of power from Austin to HL&P.
8.
All documents which relate or refer, in any way, to Docket 14 of The Public Utility Commission of Texas.
9.
All documents which relate or refer, in any way, to the receipt or sale of electric power in interstate commerce by LCRA.
- 10. All documents which relate or refer, in any way, to LCRA's service of potential or existing customers in the TPUC multiple certified areas.
368 320 e
Civil Subpoena To Testify Stuileh E.a,,tes of Amerita NUCLEAR REGULATORY COMMISSION T
in the matter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
)and 2)
Ralph Heyler Lower Colorado River Authority P.O.
Box 220 Austin, Texas 78767 YOl] ARE IlEltE.T COMMANDED to appear a t noom......U.2.,,,, ?,,q.9..E.u.t.. A.th...S.t r.c 9.t...............
i n t he c i ty o r..... Au,s,t in,,,,,Tg,x a, p,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.. 3,0,th.....duy of.....Q.Q.t9.l.9.E.........19.2.9....at.....QD.O.......o'c1ock P.M.
d to testify in the alme entitled action, (and thereaf ter from day to day, if necessary).
e ilY O'(DElt 01' Tile ATOMIC sal'ETY AND 1.1 CENSING llOAl(D IfY _
Susan B.
Cyphert Ronald H.
Clark Alturney for Angstrunt Divisio.e
...........................19........
l'M 8 de l Staf c a Department 0[.lustice
. na.hinalon,(n.c. gosanrelephone. 202J.. 22d..6d.72/6 3 61 (202) 724-6616 368 '321 10 C.V.it. 2.720 (0 presidine officer or, if he in unavadable, the On unation onade prnmplis, nml ire nov cuent Comminninn may til quanh or modtfy the nub-at or before the time specified in'the subpoena poena if it is unreasonahic or requiren evidence for compliante by the person to schwn the sub-not relevant to any matter in innue, or (21 con-poerus in siirreled, avut on nalire in the party at dition denial of the matinen on just aml reasonable whnne instance the subpoena uan issued, the terme.
9 CIVi!. SUliPOEN A 'IT) PitOlH CK DOCUMENT OR OllJECT 3tnileh Eales of Amerita p
NUCLEAR REGULATORY COMMISSION 1
Y h the rnatter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOC',KMT NOS
- 50-498A CENTRAL POWER & LIGHT COMPANY L
50-499A (South Texas Project, Units Nos.
and 2)
O Ralph Heyler Lower Colorado River Authority P.O.
Box 220 Austin, Texas 78767 YOU ARE ilEREHY COMMANDED to apperir at nem. 7.s,?,,,,,,3,Q,Q,,,E,a s,t,,,8,gh,,ltye,e,p,,,,,,,,,,,,,,,,,,,
i n t h e c i ty o f.......... A.V.s,(i,h,,,Tp,g p,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.....E.tM... day of...D.C.tobdI............19...'/.R..at....1Q.Q.Q.a'eIock A. M.
to testify in the pixwe e. titled action and bring with you the document (s) or object (s) descrilini in the attached schedule. (and thereaf ter f rom day to day, if necessary).
ilY ORDER CI' TilM ATOMIC sal'ETY AND l.ICENSING ltOARD I A*
Susan B. Cyphert Ronald H.
d a rle Alt.orney (nr Antstrust l)tt in con
............................I9........
l 'n rie d.Nt otr e Deporfme'nt of.fustire is anhenoeton D.C. 20$30 Telephone.42M2).. 724n6472/6361 (202) 724-6616 368' 322 10 C.V.u. 2.720 (n tresidiva officer nr. i! he in ws:wnilnt.te, the On onation made prompth, und in any et ent Comminninn mnv Ill quanh or modt[v the nuh-nt or before the time op. col.ed in't te esoporno poena if it en tonreanonalde or requiren evidence i
(or cornplinnre by the person 80 schwn the sub-not felt.. ant to any matter in innue, or f29 con-porr~ ;~ riirerted, arts.' on natire in the party at dition dtninl of the motion on just and reasonable who nelance the subpnenn wan is etsed the
- terme,
SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all 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 co respondence, telegrams, notes or sound re cordings of any type of conversation, meeting or con-ference, minutes of directors' or comnittee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summeries and results of investigations and tests, reviews, contractc, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
- 4. "TP&L" means Texas Power and Light Company.
5.
"DP&L" means Dallas Power & Light Company.
6.
"TESCO" means Texas Electric Service Company.
7.
"HI P" means Houston Lighting & Power Company.
- 8. " CPS" means the City Public Service Board of San Antonio.
9.
"CP&L" means Central Power and Light Company.
368 323
- 10. "WTU" means West Texas Utilities Company.
- 12. "LCRA" means Lower Cclorado River Authority.
- 13. "TPUC" means The Public Utility Commission of Texas.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which inc?.udes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraphIs) of this subpoena to which such documents responds.
III.
INSTRUCTIONS RF9ARDING GROUPING AND NUMBETdN'J DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order te facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious returr of these documents to the company.
368 324 4
Should any questions arise concerning this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Department of Justice P.O.
Box 14141 Washington, D.C.
20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to efforts by LCRA to have TU, TP&L, DP&L, TESCO, and HL&P close their interconnections with LCRA.
3.
All documents which relate or refer, in any way, to TU, TP&L, DP&L, TESCO, and HL&P's response to LCRA regard-ing LCRA's request for the closing of interconnections before May 2, 1977.
4.
All documents which relate or refer, in any way, to:
(a) LCRA's projected loads for 1980-1985; (b) LCRA's projected generation capacity for 1980-1985; (c) LCRA's p ajected load for 1980-1985; (d) any requests by or contracts with an electric power system to purchase any type of power from LCRA.
5.
All documents which relate or refer, in any way, to LCRA's fuel contracts or any fuel contracts that are pre-sently being negotiated.
6.
All documents which relate or refer, in any way, to any electric rate comparison studies. 368 325
t 7.
All documents which relate or refer, in any way, to transmittal of power from Austin to HL&P.
8.
All documents which relate or refer, in any way, to Docket 14 of The Public Utility Commission of Texas.
9.
All documents which relate or refer, in any way, to the receipt or sale of electric power in interstate commerce by LCRA.
- 10. All documents which relate or refer, in any way, to LCRA's service of potential or existing customers in the ';PUC multiple certified areas.
368 326 Civil Subpoena To Testifv a-Eini2eb fE.a.lca of Amerita I
"JCLEAR REGULATORY COMMISSICN t
Y in the matter of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
and 2)
)
Sim Gideon Lower Colorado River Authority P.O.
~ ' ~YOll ARE IIEREHY COMMANDED to an> car a t Room......U.2,,,,.,3,0 9,,,E,qp,t,, R,th,,,S,y, y,g g,t,,,,,,,,,,,,,,,
i n t h e c i ty o f....b u,g,t,i,n,,,, Tgy,g g,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.. 3,0,t.D....duy of...gc,to,be,r............19.2.9....at.....I.I.i.n,p,,,,,o cloe k A.M.
to testify in the nt we entitled action. (and thereaf ter from day to day, if necessary).
llY OltDim OF TilK NintlC SAFETY AND t.! CENSING llOA.us ifY Susan B.
Cyphert Ronald H. Clark Asturnen for Anistrunt Divisiurs t'niIed, tatcn UepnrImeni o[ Justicr
..........................1d........
. Washington.(D.C. 20530 202.)..22.4. 64.72/6361 Tercphonc..
(202) 724-6616 368 327 10 C.V.n. 2.720 'n receidina otticer or if he in w,nunitarde, Ihe On unation made promptly, *snd in aves event Comminnian any !!I quanh or modify ti.e nub.
at or before the time specified in'the nubporna
('ocna if it is un.casonable or requires evidence for compliance by the person to schorn the sub=
not relevant In any matter in inrue. Or (21 con-poena in diverted. arsd on. otice to the party at dition denial of the motion on it.sg and reasonable whnne instance the subpoenn uun innued, the terme.
4 civil. SUHPOEN 4 'ID l'etODI CE lx)CUMENT OR OluECT 1hileh 9 tales of Amerita il NUCLEAR REGULATORY COMMISSION 4
Y ln the mattler of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTI?/ and DOCKF.T NOS. 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
gand2)
Sim Gideon Lower Colorado River Authority P.O.
Box 220 Austin, Texas 78767 YOU AllE HEltt'.tW COMMANDED to appelr at Room.... 7. 5. 2.a.... '!'.0...EA.9.t...R th..S.txes t...............
it, the cit o f......^ 9.s u i n,,,,, T e,y,a,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the... 5,t,h..... day of.... 0,c 3;g,bg,r...........19.. 7.9..a t.......Tg n....o' clock e
A.M.
to testify' in the nbove entitled action nnd bring with you the doeuraent(s) or object (s) descritel in the attached schalute. (and thereafter from day to day, if necessary).
IlY OHI)Mit 01' Tile ATOMIC sal'ETY AND I lCENSING llOARD llY Susan B. Cyphert Ronald H.
Clark AIInortter for A ntstrun t Useiniton VniIed.% atcn DepnrIment o(.It:a tiee
..........................19........
\\t'an hington. D.C. 20$M Telephone.42.02.).. 72.4n 6.472/6 3 61 (202) 724-6616 3[)8 7%
e 10 C.Y.lt. 2.720 (n presiding otti< er or, it he in u.,neniinble. she On onnlion made promptl%, and in nos co ent Comminninn mnv til qunnh or modify the nule al or befurt the time spectlied sn t*te subpoeno poenn if il an unreannnable or retjuiren en idence for compliance by the person 80 GLh0m lhe Cube nul rC$CL anl 13 any maller in innur Dr(20 (Une g
poenn in dirreted, arnd on notice to the party at dition denial of the motion on just and reasonabic
' w.'sase instance the subpne nn wan iseurd, the te rm s.
V SCHEDULE I.
DEFINITIONS
- 1. " Document" means, without limiting the generality of its meaning, all original (or copies where originals are unavailable) 'nd non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, howesar produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the cther.
4.
"TP&L" means Texas Power and Light Company.
- 5. "DP&L" means Dallas Power & Light Company.
6' "TESCO" means Texas Electric Service Company.
7.
"HL&P" means Houston Lighting & Power Company.
8.
" CPS" means the City Public Service Board of San Antonio.
- 9. "CP&L" means Central Power and Light Company.
368 329
10.
"WTU" means West Texas Utilitier Company,
- 12. "LCRA" means Lower Colorado River Authority.
- 13. "TPUC" means The Public Utility Commission of Texas.
II.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph (s) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped eccording to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should oe arranged, as mach as possible, in chronological order.
In order to facilitate the handling of the dm uments which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggr.sted that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedu re, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate ar.d expeditious return of these documents to the company. 368 330
Should any questions arise concerning' this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address:
Department of Justice P.O.
Box 14141 Washington, D.C.
20044 DOCUMENTS TO BE PRODUCED 1.
All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to efforts by LCRA to have TU, TP&L, DP&L, TESCO, and HL&P close their interconnections with LCRA.
3.
All documents which relate or refer, in any way, to TU, TF&L, DP&L, TESCO, and HL&P's response to LCRA regard-ing LCRA's request for the closing of interconnections before Ma 2,
1977.
4.
All documents which relate or refer, in any way, to:
(a) LCRA's projected loads for 1980-1985; (b) LCRA's projected generation capacity for 1980-1985; (c) LCRA's projected loal for 1980-1985; (d) any requests by or contracts with an electric power system to purchase any type of power from LCRA.
5.
All documents which relate or refer, in any way, to LCRA's fuel contracts or any fuel contracts that are pre-sently being negotiated.
6.
All documents which relate or refer, in any way, to any electric rate comparison studies.
368 331
_3_
T 7.
All documents which relate or refer, in any way, to transmittal of power from Austin to HL&P.
8.
All documents which relate or refer, in any way, to Docket 14 of The Public Utility Commission of Texas.
9.
All documents which relate or refer, in any way, to the receipt or sale of electric power in interstate commerce by LCRA.
- 10. All documents which relate or refer, in any way, to LCRA's service of potential or existing customers in the TPUC multiple certified areas.
363 332.
a Civil Subpoena To Testify hileb Bl. airs of America p
t4UCLEAR REGULATORY COMMISSION A
y in the tr.ntler of:
HOUSTON LIGHTING & POWER COMPANY Tile CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET Nos. 50-498A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
}gand 2)
H.
L.
Peterson City of Austin Electric Utility Department P.O.
Box 1088 Austin, Texas 78767 YOU AllE ilEl(EHY COMMANDED to appear
~
at noorn. 75.7.,.. 3 99.., Tam.t.. A.th...S.tnnn.t.................
in t h e c i ty o f.....A u,s,,tj i n,,,,,Tg,x, a g,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.....9.t,h....duy of...... 9S.ggbRI........19.2.9....a t.....@.D 9....o'cIock A. M.
to testify in the aluwe entitled action. (and thereafter from day to day, if necessary).
IlY OltDl;lt Ol' Tili' ATtWIC SAIT.TY AND !.! CENSING llOAltD IN _
Susan B. Cyphert Ronald H.
Clark A ttorney (nr Antstrun t Un in son l'n used State n Department of.lustict'
.""""""="""""\\0*"**
. wa.hinuton.(n.c. 20s30202.)..224..64.72/6361 Triephnne..
(202) 724-6616 10 C.V.R. 2.720 (0 presidinn officer or, if he in unnvadahic. the On one.ston madt promptly, nnd in nosv event Comminninn mns til qunnh or modify the nub-at or before the time specified sn'the suhporna poena liit is unreasonable or regnates evidence for compliance b_x the person to schorn the sub-noi rcles arnt to any matter in issue, or (21 con.
poena is riirected, and on notice to the party at dition denial of the motion on just and reasonable u hnse instance the subpornn was insurd. the te rm s,
e Civil. SUHl'OEN A TO PHOlH CE LOCUMENT OH OluECT I!nileh 91. ales of Amerita p
NUCLEAR REGULATORY COMMISSION j_
in the rnattur of:
IIOUSTON LIGilTING & POWER COMPANY THE CITY OF SAN ANTONIO TIIE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
,gan02)
H.
L.
Peterson City of Austin Electric Utility Department P.O.
Box 1088 Austin, Texas 78767 YOU AltB llEltEHY COMMANDED to appent a t noom.. 2.5.2.,,,, s, p, p.. E.03.t.. !1.4 h...S.tr.c 9.t.................
i n t h e c i ty o f........^.Y.s t,i n,,,,T,e y,,s,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the.....E.$D....duy t'f.... 9910.DQ T..........19... 7.9..nt....N.i.ne....o' clock A.M.
to testify in the nluwe entitled action and bring with you the document (e) or object (s) described in the attached schedule. (and thereafter from day to day, if necessary).
- n. ORDElt OF Tile ATOMIC sal'ETY AND t.trENSING HOAl(D IfY Susan B. Cyphert Ronald H.
Piark o\\tl.ornes [nr o\\ntstroen t list in surt
............................I9......
t 'nieed SIatc e Deonrtme,a o(.Iu e tiee Manhington, D.C. 20S*lo Televhanc.42.024.. 32An 6472/6 3 61 (202) 724-6616 10 C.Y.lt. 2.720 (0 presirline nitiver nr. If he i' unneniin!.le, the Cn matinn artnole promptls, nnel in nous vs ent Commun ni..., mas til q. cnh or matitfy the nule at or 1.cfore the time up. colord in'the sulpnena pnenn if it in unreasonesble or rr <;noren evi.u rce for compliance by the frrson in u horn the sub.
not relevant in any matter its innue, or (29 cc g.
puerus in riirected, artsi on notice to the party at dition drnini of the malian on just anel reang table u hose instance the subptwnn suun issued, the
- terms,
SCHEDULE I.
DEF1NITIONS 1.
" Document" means, without limiting the generality of its meaning, all 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 con-ference, 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, inc.luding preliminary versions, drafts or revisions of any of the toregoing and any supporting, underlying or prepatatory Edterial.
2.
" Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other.
3.
"TU" means Texas Utilities Company.
4.
"TP&L" means Texas Power and Light Company.
5.
'DP&L" means Dallas Power & Light Company.
6.
"TESC0" means Texas Electric Service Company.
7.
"HL&P" means Houston Lighting & Power Company.
8.
" CPS" means the City Public Service Board of San Antonio.
9.
"CP&L" r.aans Central Power and Light Company.
368 335
9 10.
"WTU" means West Texas Utilities Company.
- 12. "LCRA" means Lower Lolorado River Authority.
- 13. "Brazos" means Brazos Electric Power Cooperative, Inc.
- 14. " Wheeling" means the transportation of electricity by e utility over its lines for another utility; also includes the receipt from and delivery to another system of like amounts but not necessarily the same energy.
- 15. " Economy Energy" means energy produced and supplied from a more economical source, substituted for energy that could have been produced by a less economical source.
II.
CLAIM OF PRIVILEGE If ?.ny document is withheld under claim of privilege, fucnish a list which identifies each document for which privilcea is claimed and which includes the folJowing inform en for each such document: date, subject matter, sendet
- ecipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraphls) of this subpoena to which such documents responds.
III.
INSTRUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
368 336
-2_
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate.
This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
Should any questions arise concerning this subpoena, please contact Susan B.
Cyphert (202-724-6472 or 724-6361) or Ronald H.
Clark (202-724-6616) at the following address:
Department of Justice P.O. Box 14141 Washington, D.C.
20044 DOCUMENTS TO EE PRODUCED 1.
A]l documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, and HL&P with CPS, CP&L, WTU, Austin, and LCRA.
2.
All documents which relate or refer, in any way, to efforts by Austin to have TU, TP&L, DP&L, TESCO, and HL&P close their interconnections with Austin.
3.
All documents which relate or refer, in any way, to TU, TP&L, DP&L, TESCO, and HL&P's response to Austin regard-ing Austin's request f o r.
the closing of interconnections before May 2, 1977.
4.
All documents which relate or refer, in any way, to:
(a) Austin's projected loads for 1960-1985; (b) Austin's projected generation tegecity for 1980-1985; (c) Austin's projected load for 1980-1985; (d) any requests by or contracts with an electric power system to purchase power from Austin.
368 337 5.
All documents which relate or refer,
'n any way, to Austin's fuel contracts or any fuel contracts (nat are presently being negotiated.
6.
All documents which relate or re fer, in any way, to any rate comparison studies that have been done.
7.
All documents which relate or refer, in any way, to the San Miguel plant and the transmission system Brazos is building from San Miguel to transmit power from San Miguel to the Brazos load centers.
8.
All documents which relate or refer, in any way, to the receipt or sale of electric power in interstate commerce by Austin.
9.
All documents which relate or refer, in any way, to the wheeling of power for or to a Texas electric utility.
- 10. All documents which relate or refer, in any way, to economy energy transactions.
368 338
_4_
Civil Subpoena To Testify
~
Ilnileb &. ales of Amerita go NUCLEAR REGULATORY COMMISSION 1
y in the mntfer of:
HOUSTON LIGHTING & POWER COMPANY THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET Nos. 50-4 98 A CENTRAL POWER AND LIGHT COMPANY 50-499A (South Texas Project, Units Nos.
gand2)
B.
L.
Hancock City of Austin Electric Utility Department P.O.
- ---YOU ARE IIEllEBY COMMANDED to an> ear
- 7. 5. 2..,... 3. 0. 0.... F.a..s..t... 8..t..h.....S..t..r..e..e..t................
at Room......
i n t h e c i ty o f...... S H.s,t,i,n,,,,,Tg x a,s_,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
on the...l.0.th...duy of....Qctober.......... 19.29....at...Ninn......o' clock A. M.
to testify in the nbove entitled action - (and thereaf ter from day to day, if necessary).
ILY OltDI:lt OF Tile ATOMIC sal'ETY AND 1.WENSING BOAl(D IfY Susan B. Cyphert Ronald H.
Clark
,uuurnev tar Antstrunt owi,iva
"*""""""""""'g9'""'
e nited.suarc. Department o.tuntice r
. wa.hinuton (o.c. 20s30202)..224..642.2/6361 Terc,, hone..
(202) 724-6616 3g
, 10 C %R. 2.720 (n prenuins officer or, if he is unnenannte, the 0, tion made prompris. nnd in n.uv ce,ent Commis alon mnv til nunnh or modofy the nuh-at or are the time specified ir ~the subpoena poena if it is un<canonable or requires evidence for es ' inner by, the person to tehoon the sub-not relevant in any mattes in instne, or (21 con. dil nn denial of tha motion en just and reasonable l pornu. iirected, anit on notice in :he party at schase instance the suhpoo na asan innu:{ the terms. r
civil. SOHI OEN A TO PitODI CM DOCUMENT OR OBJECT linileb 9t.a,,les of America NUCLEAR REGULATORY COMM L:c>10N 1 y la the matt 4 r of: HOUSTON LIGHTING & POWER COMPANY 7 THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and DOCKET NOS. 50-498A CENTRAL POWER & LIGHT COMPANY 50-499A (South Texas Project, Units Nos. 1 and 2') TO R. L. Hancock City of Austin Electric Utility Department P.O. Box 1088 Sustin, Texas 78767 YOU AllE IIEltEHY COMMANDED to appent at noom.... 7.5.L.. 3DD..Kaat..R.t.h.,,s,tgggf i n th e e s 'y of........A..u...s. t..i..n..,...T..e.. x..a..s................................................... on the..E.$D.......ciuy of... 9S.$9.D.9E...........19.. 7.9..nt....I !.3,,Q.....o' clock A. M. to testify in the alrwe entitled action and bring with you the document (s) or object (s) descrilel in the attached schedule. (anc' thereaf ter from day to day, if necessary). llY ORDl;H 01' Tile ATOMIC sal'KTY AND I.lCENSING HOAl(D m* Susan B. Cyphert Ronald H. Clark Allarnes for Antstrennt Ost ta son t 'n ited.%tatc o Department of.luatice
- """"*""""""'39"""
u anhingtors. D.C. 20530 Telephone..(2.02.1.. 224n6472/6 3 61 }fg }gUn (202) 724-6616 10 C.Y.ll. 2.720 (n twesiding officer or, if he i< unavailable. the On unntion made promptis, twl ins nns event Comminninn mnv til quanh or modtfv the nn!- at or before the time n,peenf oed in the es& porno poena if it in unreasonabic or requeren en idence for compliartee hy; the person la nham thr* sub-not relen ant to any matter in inene, or 42I con. i pocrut in directed. artd on nnlier in t re party al dition denial of the motion on just and reasonable whnse ins tance ll:e subpoenn was issued, the
- terme,
- w. - e -... -
SCHEDULE I. DEFINITIONS 1. " Document" means, without limiting the generality of its meaning, all original (or copies where originals are unavailable) and non-identical copies (whether different from origin'ls 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 con-ference, minutes of directors' or committee meetingn, memoranda, inter-office communications, studies, anal.yses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or prepa atory material. 2. " Interconnection" means a transmission line joining two or more power systems through which power produced by one can be used by the other. 3. "TU" means Texas Utilities Company.
- 4. "TP&L" means Texas Power and Light Company.
5. "DP&L" means Dallas Power & Light Company. 6. "TESCO" means Texas Electric Service Company. 7. "HL&P" means Houston Lighting & Power Company. 8. " CPS" means the City Public Service Board of San Antonio. 9. "CP&L" means Central Power and Light Company. 368 341
- 10. "WTU ' manns West Texas Utilities Company.
- 11. " Austin" means City of hustia.
- 12. "LCRA" means Lower Colorado River Authority.
- 13. "Brazos" means Brazos Electric Power Cooperative, Inc.
- 14. " Wheeling" means the transportation of electricity by a utility over its lines for another utility; also includes the receipt from and delivery to ancther system of like amounts but not necessarily the same energy.
- 15. " Economy Energy" means energy produced and supplied from a more economical source, substituted for energy that could have been produced by a less economical source.
II. CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which pri vilege is claimed, and the paragraph (s) of this subpoena to which such documents responds. T;I. INS? RUCTIONS REGARDING GROUPING AND NUMBERING DOCUMENTS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order. 368 342
~... In order to facilitate the handling of the documents which wil) be received it would be appreciated if each of the documents would be numbered consecutively. It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate. This procedure, if followed, will preserve the identity of all the documents coming from the com.any, and also insure the accurate and expeditious return of these documents to the company. Should any questions arise cancerning this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Ronald H. Clark (202-724-6616) at the following address: Department of Justice P.O. Box 14141 Washington, D,C. 20044 DOCUMENTS TO BE PRODUCED 1. All documents which relate or refer, in any way, to the May 4, 1976 opening of interconnections by TU, TP&L, DP&L, TESCO, ano UL&P with CPS, CP&L, WTU, Austin, and LCRA. 2. All documents which relate or refer, in any way, to efforts by Austin to have TU, TP&L, DP&L, TESCO, and HL&P close their interconnections with Austin. 3. All documents which relate or refer, in any way, to TU, TP&L, DP&L, TESCO, and HL&P's response to Austin regard-ing Austin's request for ';he closing of interconnections before May 2, 1977. 4. All documents which relate or refer, in any way, to: (a) Austin's projected loads for 1980-1985 a) Austin's projected generation capacity for 1980-1985 Austin's projected load for 1980-1985; (d) any requests by or contracts with an electric pcuer system to purchase power from Austin. }68 343 5. All documen' which relate or refer, in any way, to Austin's fuel contracts or any fuel contracts that are presently being negotiated. 6. All documents which relate or refer, in any way, to any rate comparison studies t2:at have been done. 7. All documents which relate ot refer, in any way, to the San Miguel plant and the transmission system Brazos is building from San Miguel to transmit power from San Miguel to the Brazos load centers. 8. All documents which relate or refer, in any way, to the receipt or sale of electric power in interstate commerce by Austin. 9. All documents which relate or refer, in any way, to the wheeling of power for or to a Texas electric utility.
- 10. All documents which relate or refer, in any way, to economy energy transactions.
- 11. All documents which relate or refer, in any way, to Austin's service of potential or existing customers in the TPUC multiple certified areas.
- 12. All documents which relate or refer, in ainy way, to:
(a) the intrcstate only restricticas four.d in the contracts Austin has with HL&P and the TU com-panies; (b) a memorandum from Richard Balough to R.L. Hancock, dated March 13, 1979, pertaining to the sale of power to Houston; (c) a letter from Dumas, Huguenin, Boothman and Morrow to Richard Balough, dated February 19, 1979, pertaining to the intrastate only restrictions in existing contracts and in cont acts recently being negotiated. )bO }}