ML19260E079

Motion for Protective Order in Favor of Carter Oil Co Re Documents Produced in Response to 791024 Subpoena Directed to Ib Phillips for 791116 Deposition.Stipulation Between Parties,Dtd 791116 Encl

ML19260E079
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	01/28/1980
From:	Fountain K, Plummer J AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19260E080	List: ML19260E079 ML19260E085
References
NUDOCS 8002130305
Download: ML19260E079 (2)

Text

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UNITED STATES OF AMERICA T tws*1 2:

NUCLEAR REGULATORY COMMISSION G ## '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: I I

HOUSTON LIGHTING & POWER l COMPANY, THE CITY OF SAN I ANTONIO, THE CITY OF i NRC DOCKET NOS. 50-498A AUSTIN, and CENTRAL POWER l 50-499A AND LIGHT COMPANY l l

(South Texas Project, i Unit Nos. 1 and 2) l In the Matter of: 1 TEXAS UTILITIES l GENERATING COMPANY, i NRC DOCKET NOS. 50-445A ET AL l 50-446A 1

(Comanche Peak Steam l Electric Station, l Unit Nos.1 and 2) l MOTION FOR PROTECTIVE ORDER In connection with the deposition in Houston, Texas, on November 16, 1979 of James Barney Phillips, employee of Exxon Coal USA, Inc. (The Synthetics Fuels Department of The Carter Oil Company was transferred, effective January 1, 1980, to a new subsidiary of Exxon Corporation, Exxon Coal USA, Inc.f .

and with the production of Carter Oil documents at that time, both pursuant to subpoena issued by the Atomic Safety and Licensing Board (the " Board"), a stipulation was entered into between the attorneys representing the Department of Justice, Houston Lighting & Power Company, Texas Utilities Generating 8002180

Company, Central Power and Light Company, Tex-La Electric Cooperative of Texas, The Carter Oil Company, and the Nuclear Regulatory Commission. In the stipulation, these parties agree to a protective order governing use and dissemination of certain of the produced documents and certain responses of the witness in the deposition transcript, which documents and transcript portions contain information of a confidential and proprietary nature. Further, during the deposition and after signing of the stipulation, the parties agreed, and the transcript so reflects on page 20, that the entire deposition testimony should be subject to the restrictions of the protective order.

We hereby move the Board to issue the order contained in the stipulation, a copy of which is attached hereto, with the order further to note that the entire deposition testimony is protected thereby. Copies of this motion have been served on the parties to the captioned proceeding as listed on the attached Certificate of Service.

This motion is respectfully submitted by the following legal counsel for Exxon Coal USA, Inc.:

LA 6? FA Kenneth P. Fountain (byp.ee)

J. Paul Plummer P. O. Box 2180 Houston, Texas 77001 a