ML19270F288
| ML19270F288 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 01/18/1979 |
| From: | Tom Ryan ISHAM, LINCOLN & BEALE |
| To: | |
| References | |
| NUDOCS 7902060124 | |
| Download: ML19270F288 (52) | |
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0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIONl 4 Q
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In the Matter of ) . .-
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HOUSTON LIGHTING AND POWER CO. , )
et al. ) Docket Nos. 50-498A
) 50-499A (South Texas Project, Units )
No. 1 and 2) )
)
)
)
In the Matter of )
)
TEXAS UTILITIES GENERATING COMPANY,) Docket Nos. 50-445A et al. ) 50-446A
) CONSOLIDATED FOR DISCOVERY (Comanche Peak Steam Electric )
Station, Units 1 and 2) )
TO: Marshall E. Miller, Esq., Chairman Atomic Safety & Licensing Board Panel APPLICATION FOR ISSUANCE OF SUBPOENAS Central Power and Light Company, pursuant to 10 C.F.R. S2.720, hereby raakes application for the issuance of subpoenas, attached hereto, as follows:
Schpoenas for Deposition (1) Robert L. Wright, Union Carbide Corporation (2) Lee C. Peeler, Monsanto Company (3) Robert H. Steder, PPG Industries, Inc.
(4) Edward V. Sherry, Air Products and Chemicals, Inc.
(5) A.D. Cyphers, E.I. DuPont de Nemours
& Co.
7 9 0 2 0 6 0 l;>*\ !
f Subpoenas for Production of Documents (1) Keeper of the Records, Union Carbide Corporation (2) Keeper of the Records, Monsanto Company (3) Keeper of the Records, PPG Industries, Inc.
(4) Keeper of the Records, Air Products and Chemicals, Inc.
(5) Keeper of the Records, E.I. DuPont de Nemours
& Co.
The subpoenas call for depositions and production of documents which are relevant to the general issue of competition in the electric utility industry and, in particular, in Texas and adjacent areas. The documents requested for production are those which indicate the concern of these industrial companies with electricity costs, rates, reliability of service and availability of service. These docuinents may also indicate the impor-tance of these factors in the companies' siting or location decisions, as well as the efforts by elect.ric utilities in Texas and elsewhere to encourage the location of plants or facilities in a utility's service territory.
The subpoenas for depositions are directed toward representatives of industries with plants or facilities in Texas. The deponents have presented testimony before the Public Utility Commission ("PUC") of Texas in Docket
No. 1776 (the generic rate hearings) concerning the importance of electric utility rates and reliability of service to their Texas-based plants or facilities. In general, the depositions are intended to explore cnd develop further the PUC testimony, as this testimony is clearly germane to the ccmpetition which exists in the electric utility industry in Texas.
Central Power and Light Company requests that this Board sign the enclosed subpoenas and return them to the undersigned at Isham, Lincoln & Beale, Chicago, Illinois.
Respectfully submitted, By Thomas G. Ryan One of the Attorneys for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 1050 17th Street, N.W.
Seventh Floor Washington, D.C. 20036 (202) 833-9730 Dated: January 18, 1979
STATE OF ILLINOIS )
) SS COUNTY OF COOK )
CERTIFICATE OF SERVICE I hereby certify that copies of " Application for Issuance of Subpoenas" in the captioned matters were served upon the following persons by deposit in the United States mail, first class postage prepaid, this 18th day of January, 1979.
Marshall E. Miller, Esq. (2 copies) Mr. Jerome D. Saltzman U.S. Nuclear Regulatory Chief, Antitrust and Commission Indemnity Group Fashington, D.C. 20555 U.S. Nuclear Regulatory Commission Michael L. Glaser, Esq. (2 copies) Nuclear Reactor Regulation 1150 17th Street, N.W. Washington, D.C. 20555 Washington, D.C. 20036 J. Irion Worsham, Esq.
Sheldon J. Wolf, Esq. (2 copies) Merlyn D. Sampels, Esq.
U.S. Nuclear Regulatory Spencer C. Relyea, Esq.
Commission Worsham, Forsythe & Sampels Washington, D.C. 20555 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Atomic Safety and Licensing Appeal Board Panel Jon C. Wood, Esq.
U.S. Nuclear Regulatory W. Roger Wilson, Esq.
Commission Matthews, Nowlin, Macfarlane Washington, D.C. 20555 & Barrett 1500 Alamo National Building San Antonio, Texas 78205 Chase R. Stephens (original and Charles G. Thrash, Jr., Esq.
20 copies) E.W. Barnett, Esq.
Decketing and Service Branch Theodore F. Weiss, Esq.
U.S. Nuclear Regulatory J. Gregory Copeland, Esq.
Commission Baker & Botts Washington, D.C. 20555 3000 One Shell Plaza Houston, Texas 77002
R. Gordon Gooch, Esq. Don R. Butler, Esq.
John P. Mathis, Esq. Sneed, Vine, Wilkerson, Baker & Botts Selman & Perry 1701 Pennsylvania Avenue, N.W. P.O. Box 1409 Washington, D.C. 20006 Austin, Texas 78767 Roy P. Lessy, Jr., Esq.
Michael B. Blume, Esq. Jerry L. Harris, Esq.
U.S. Nuclear Regulatory Richard C. Balough, Esq.
Commission City of Austin Washington, D.C. 20555 P.O. Box 1088 Austin, Texas 78767 Roff Hardy Chairman and Chief Executive Don H. Davidson Officer City Manager Central Power and Light Company City of Austin P.O. Box 2121 P.O. Box 1088 Corpus Christi, Texas 78403 Austin, Texas 78767 Mr. Perry G. Brittain Robert Lowenstein President J.A. Bouknight, Jr.
Texas Utilities Generating William J. Franklin Company Lowenstein, Newman, Reis &
2001 Bryan Tower Axelrad Dallas, Texas 75201 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 John W. Davidson, Esq.
R.L. Hancock, Director Sawtelle, Goode, Davidson &
City of Austin Electric Utility Tioilo P.O. Box 1086 1100 San Antonio Savings Austin, Texas 78767 Building San Antonio, Texas 78205 G.W. Oprea, Jr.
Executive Vice President Douglas F. John, Esq.
Houston Lighting & Power Akin, Gump, Haver & Feld Company 1100 Madison Office Building P.O. Box 1700 1155 15th Street, N.W.
Houston, Texas 77001 Washington, D.C. 20005 Judith Harris, Esq. Morgan Hunter, Esq.
Ronald Clark, Esq. Bill D. St. Clair, Esq.
U.S. Department of Justice McGinnis, Lockridge &
Antitrust Division Kilgore 411-llth Street, N.W. Fifth Floor, Texas State Washington, D.C. 20530 Bank Building 900 Congress Avenue Austin, Texas 78701
Kevin B. Pratt Texas Attorney General's Office State of Texas William H. Burchett, Esq.
P.O. Box 12548 Frederick H. Ritts, Esq.
Austin, Texas 78711 Northcutt Ely Watergate 600 Building W.S. Robson Washington, D.C. 20037 General Manager South Texas Electric Cooperating, Robert C. McDiarmid, Esq.
Inc. Robert Jablon, Esq.
Route 6, Building 102 2600 Virginia Avenue, N.W.
Victoria Regional Airport Washington, D.C. 20037 Victoria, Texas 77901 Joseph B. Knotts, Jr. Richard D. Cudahy, Esq.
Nicholas S. Reynolds Robert H. Loeffler, Esq.
Debevoise & Liberman Joseph Gallo, Esq.
806 15th Street, N.W. Ste. 700 Isham, Lincoln & Beale Washington, D.C. 20005 1050 17th Street, N.W.
Seventh Floor Washington, D.C. 20036 Joseph Rutberg, Esq. Wheatley & Miller Antitrust Counsel 1112 Watergate Office Bldg.
Counsel for NRC Staff 2600 Virginia Avenue, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C. 20037 Washington, D.C. 20555 Joseph J. Saunders, Esq. Linda L. Aaker, Esq.
Chief, Public Counsel & Assistant Attorney General Legislative Section P.O. Box 12548 Antitrust Section Capital Station U.S. Department of Justice Austin, Texas 78711 P.O. Box 14141 Washington, D.C. 20044 G.K. Spruce, General Manager Knoland J. Plucknett City Public Service Board Executive Director P.O. Box 1771 Committee on Power for the San Antonio, Texas 78203 Southwest, Inc.
5541 East Skelly Drive Tulsa, Oklahoma 74135
Jay M. Galt, Esq. Robert E. Bathen Looney, Nichols, Johnson & IIayes R.W. Beck & Associates 219 Couch Drive P.O. Box 6817 Oklahoma City, Oklahoma 73101 Orlando, Florida 82853 John E. Mathews, Jr., Esq.
Mathews, Osborne, Ehrlich, McNatt Gobelman & Cobb 1500 American Heritage Life Bldg.
Jacksonville, Florida 32202 THOMAS G. RYAN
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Subpoena for Production of Documents ,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Keeper of the Records Union Carbide Corporation 270 Park Avenue New York, N.Y. 10017 YOU ARE HEREBY COMMANDED to make available for inspection and copying at 270 Park Avenue in the city of N'ew York, New York 10017 on the 199') .
day of . . .[?95?9EY. . . . , 19.?! . the document (s) or object (s) described in the attached schedule.
m Subpoena for Production of Documents Page Two BY ORDER OF THE ATCMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2.720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or mcdify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR PRODUCTICN OF DOCUMENTS
- 1. All documents which relate to the testimony given by Union Carbide Corporation before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of Union Carbide Corporation.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of Union Carbide Corporation.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please Provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, revi'ews, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at .............................. on
............... and on ............... at ...............
.................... served it on the within named ............
.................... by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By ..............................
Service Fees Travel ...............S Services .............S Total ................$
Subscribed and sworn to before me, a .........................
this ...... day of ..............., 19.....
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Subpoena for Production of Documents {"' _', ' -
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Keeper of the Records E.I. DuPont de Nemours & Co.
1007 Market Street Wilmington, Delaware 19801 YOU ARE HEREBY COMMANDED to make available for inspection and copying at 1007 Market Street 19th in the city of Wilmington, Delaware 19801 on the ......
day of ..[*hf? f?....., 19.?9 the document (s) or object (s) described in the attached schedule.
Subpoena for Production of Documents Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Ccmpany ISHAM, LINCOLN & BEALE Cne First National Plaza Suite 4300 Chicago, Illino:is 60603 (312) 786-7500 10 C.F.R. 2.720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR PRODUCTION OF DOCUMENTS
- 1. All documents which relate to the testimony given by E.I. DuPont de Nemours & Co. before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant
.- or facilities siting or locational decisions of E.I.
DuPont de Nemours & Co.
- 3. All documents which sitow, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of E.I.
DuPont de Nemours & Co.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, _
however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at .............................. on
............... and on ............... at ...............
.................... served it on the within named ............
.................... by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By ..............................
Service Fees Travel ...............$
Services .............S Total ................$
Subscribed and sworn to before me, a .........................
this ...... day of ..............., 19.....
t Qx - bs NRC PQ;uc - . .3 9.f Subpoena for Production of Documents UNITED STATES OF AMERICA NUCLEAR FIGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A
) 50-499A THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and )
)
CENTRAL POWER AND LIGHT COMI iNY
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Keeper of the Records Air Products & Chemicals, Inc.
P.O. Box 538 Allentown, Pa. 18105 YOU ARE HEREBY COMMANDED to make available for inspection and copying at Air Products & Chemicals, Inc.
19th in the city of Allentown, Pennsylvania 18105 on the ......
day of ..{ebzga;g,,,,,, 19,79 the document (s) or object (s) described in the attached schedule.
Subpoena for Production of Locuments Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2.720(f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub- i poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or mcdify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR PRODUCTICN OF DOCUMENTS
- 1. All documents which relate to the- testimony given by Air Products & Chemicals, Inc. cefore the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilitics siting or locationa. decisions of Air Products & Chemicals, Inc.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of Air Products & Chemicals, Inc.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date an which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power an'd Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpcena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such documen .
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not nov in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, revi'ews, 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.
" Relating to' means consisc of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at .............................. On
.............. and on ............... at ...............
.................... served it on the within named ............
. . . . . . . . . . . . . . . . . . . . by delivering a copy to h. . . . and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By ..............................
Service Fees Travel ...............S Services .............$
Total ................S Subscribed and sworn to before me, a .........................
this ...... day of ..............., 19.....
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NRC PUEUC EGCU.Z:I ROOM ff
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Subpoena for Production of Documents UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A
) 50-499A THE CITY OF SAN ANTONIO THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Keeper of the Records Monsanto Company 800 N. Lindbergh Blvd.
St. Louis, Mo. 63166 YOU ARE HEREBY COMMANDED to make available for inspection and copying at 800 N. Lindbergh Blvd.,
in the city of St. Louis, Missouri 63166 on the .lRgh ,
day of . .Fqhqqq;y , , , , , , 19,}!. the document (s) or object (s) described in the attached schedule.
Subpoena for Production of Documents Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2.720(f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR PRODUCTION OF DOCUMENTS
- 1. All documents which relate to the testimony given by Monsanto Company before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings) .
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of Monsanto Company.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of Monsanto Company.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present locati> and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of cny type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE on Received this subpoena at ..............................
............... and on ............... at ...............
.................... served it on the within named ............
.................... by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By ..............................
Service Fees Travel ..... ........S Services .............$
Total ................S Subscribed and sworn to before me, a .........................
this ...... day of ..............., 19.....
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SubP oena for Production of Documents . ,
n d,/7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Keeper of the Records PPG Industries, Inc.
One Gateway Center Pittsburgh, PA 15222 YOU ARE HEREBY COMMANDED to make available for inspection and copying at One Gateway Center in the city of Pittsburgh, Pennsylvania 15222 on the . t' 9 *! ".' .
day of . 58YfY 5?....., 19.}9 the document (s) or object (s) described in the attached schedule.
Subpoena for Productic" of Documents Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2.720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR PRODUCTION OF DOCUMENTS
- 1. All documents which relate to the testimony given by PPG Industries, Inc. before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings) .
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of PPG Industries, Inc.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of PPG Industries, Inc.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together ia the Keeper of the Records' files.
If you cle.im that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of doc-' ant; (c) identity of author and addresses; (d) present location and custodian; Ca) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential ,
nature of any such document.
" Documents" means, without limiting the generality of its meaning all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at .............................. On and on ............... at ...............
.................... served it on the within named ............
.................... by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... Ey ..............................
Service Fees Travel ...............$
Services .............$
Total ...............S Subscribed and sworn to before me, a .........................
this ...... day of ..............., 19.....
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Subpoena for Deposition ;) ,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Lee C. Peeler Monsanto Company P.O. Box 711 Alvin, Texas 77'511 YOU ARE HEREBY COMMANDED to appear et . .H,o,lp,a,y Jnn , ,
Junction Highway 6 & 35 . . Alvin
......................... In the city of .................,
. . . Texas , , , , , , , , on the 14t,h... day of
. ....".'EC'"........,
M
- 19. 9 .. at 9. *.3,0. . o' clock A.M. (and thereafter frcm day to day, if necessary) to testify on behalf of Central Power and Light Company at the taking of a deposition in the above-entitled action pending before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission and bring with you the document (s) or object (s) described in the attached schedule.
Subpoena for Deposition Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2. 72 0 ( f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose insta'nce the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR DEPOSITION
- 1. All documents which relate to the testimony given by you before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of Monsanto Company.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which snow, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of Monsanto Company.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives, Central Power and Light Company requests that the Keeper of t';.e Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical ecpies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at ............... .......... on
............... and on ............... at ............ ..
..................... served it on the within named ..........
. ................ by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By.........................
Service Fees Travel ..................$
Services ................S Total ...................$
Subscribed and sworn to before me, a .......................
this .... day of ..............., 19....
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Subpoena for Deposition ,\/
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V UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND PCWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Robert L. Wright Union Carbide Corporation Chemicals and Plastics Division P.O. Box 185 Port Lavaca, Texas 77979 YOU ARE HEREBY COMMANDED to appear at .Bes
, g ,Wes, , p e nt Shellfish
- Inn
.qhway, }5, ,N,oygh,, Bg:,c ,2,2,7. . . . . in the city of P 9 .r.t , M y a p ,a , , , , , , ,
............... on the .16.th. day o.c . . M. a. .r c h. . . . . . . . . ,
19..I9 .. at 9.:.3,0.. o' clock A.M. (and thereafter from day to day, if necessary) to testify on behalf of Central Power and Light Company at the taking of a deposition in the above-entitled action pending before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission and bring with you the document (s) or object (s) described in the attached schedule.
Subpoena for Deposition Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2. 720 ( f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he,is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR DEPOSITION
- 1. All documents which relate to the testimony given by you before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of Union Carbide Corporation.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of Union Carbide Corporation.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) pr'sent location and custodian; (e) any other description necessary to enable the curtodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at ................... ....... on
............... and on ............... at ...............
.............. ...... served it on the within named ..........
......... ........ by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By........ ................
Service Fees Travel ..................$
Services ... ............$
Total ............. .....$
Subscribed and sworn to before me, a . .....................
this .... day of ..............., 19....
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Subpoena for Deposition X-1, ,/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE C fY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Robert H. Steder PPG Industries, Inc.
One Gateway Center Pittsburgh, Pennsylvania 15222 YOU ARE HEREBY COMMANDED to appear at F.ilMam.Vggn Hotel, P.O. Box 1978, Mellon Sqaure
......................... In the ci ty o r . .P.i.tt. ab.u.r.gh. . . . . . . . ,
Pennsylvania on the . 2 3. r.d. . day of . . . . M.a.r.ch. . . . . . . . ,
- 19. 79 .. at 9. .3 0. . o' clock A.M. (and thereafter from day to day, if necessary) to testify on behalf of Central Power and Light Company at the taking of a deposition in the above-entitled action pending before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission and bring with you the document (s) or object (s) described in the attached schedule.
a u_ f v e..a ___ -_y-e__.u..
Page Two BY OPDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires esidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR DEPOSITION
- 1. All documents which relate to the testimony given by you before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of PPG Industries, Inc.
- 3. All documents which show, describe or relate to any comparisons, nntrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of PPG Industries, Inc.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection ar-1 copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific regt.est or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you clain that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; ,
(d) present location and custodian; (e) any other description necessary to enable the castodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made en such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at ........................... on
............... and on ............... at ...............
..................... served it on the within named ..........
.................. by delivering a copy to h... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Jated ............. 19.... By.........................
Service Fees Travel ..................$
Services ................$
Total ...................S Subscribed and sworn to before me, a .......................
this .... day of................, 19....
s NRC 1-L - .
Subpoena for Deposition UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: A.D. Cyphers, P,lant Manager E.I. DuPont de Nemours & Co.
P.O. Box 2626 Victoria, Texas 77907 YOU ARE HEREBY COMMANDED to appear at Egitdpy,Iqq, F.0,5, h ,Ho,usto,n.............
in the city of .V.i.c ; o r,ip, , , , , , , , , , ,
...T,eyqs......... on the 15 gh . . day of ..Ugr,c,h,,,,,,,,,,
9:30 (and thereafter from day to
- 19. 79 at ...... o' clock A.M.
day, if necessary) to testify on behalf of Central Power and Light Company at the taking of a deposition in the abcve-entitled action pending before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission and bring with you the document (s) or object (s) described in the attached schedule.
Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOAPD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2.720(f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA FOR DEPOSITION
- 1. All documents which relate to the testimony given by you before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of E.I.
DuPont de Nemours & Co.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of E.I.
DuPont de Nemours & Co.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Cantral Power a'd n Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custo;ian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter di scussed.
RETURN ON SERVICE Received this subpoena at .... ........... .......... on
............... and on ..... ......... at ...............
..................... served it on the within named ....... ..
.................. by delivering a copy to h.... and ten-dering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated .............. 19.... By.........................
Service Fees Travel ..................$
Services ................$
Total ...................$
Subscribed and sworn to before me, a .......................
this .... day of'..............., 19....
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Subpoena for Deposition N- ' . -- . - _ -
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UNITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSION In the Matter of )
)
HOUSTON LIGHTING AND POWER COMPANY ) Docket Nos. 50-498A THE CITY OF SAN ANTONIO ) 50-499A THE CITY OF AUSTIN and )
CENTRAL POWER AND LIGHT COMPANY )
)
(South Texas Project, Units Nos. )
1 and 2) )
SUBPOENA TO: Edward V. Sherry, Director of Power Supply Air Products and Chemicals, Inc.
P.O. Box 538 Allentown, Pennsylvania 18105 YOU ARE HEREBY COMMANDED to appear at .Ho,lidav, , Inn ,
. ggt,e R
2 2,a,t, ,Jync,t,1,on ,o,f, , Route. in the city of . A11.* " t "". . . . . . . . . ,
361 Pennsylvania on the 22n. d. . . day of . . .M.a r. c.h. . . . . . . . . ,
9 30 19.79. . at ...... o' clock A.M. (and thereafter from day to day, if necessary) to testify on behalf of Central Power and Light Company at the taking of a deposition in the above-entitled action pending before the Atomic Safety
~
and Licensing Board of the Nuclear Regulatory Commission and bring with you the document (s) or object (s) described in the attached schedula.
Subpoena for Deposition Page Two BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By
..............., 19....
Thomas G. Ryan Attorney for Central Power and Light Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4300 Chicago, Illinois 60603 (312) 786-7500 10 C.F.R. 2. 720 ( f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the sub-poena is directed, and ou notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the sub-poena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) con-dition denial of the motion on just and reasonable terms.
+w
SCHEDULE TO SUBPOENA FOR DEPOSITION
- 1. All documents which relate to the testimony given by you before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings) .
- 2. All documents which show, describe or relate to the consideration accorded electric utility rates, costs, reliability of service or availability of service in plant or facilities siting or locational decisions of Air Products and Chemicals, Inc.
- 3. All documents which show, describe or relate to any comparisons, contrasts or studies the objective of which, in whole or in part, was to assess or evaluate different electric utility companies in terms of rates, costs, reliability of service or availability of service.
- 4. All documents which show, describe or relate to attempts on the part of any eluctric utility operating, in whole or in part, in Texas to provide electric service to prospective or current plants or facilities of Air Products and Chemicals, Inc.
Instructions The period of time for which documents are requested includes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Central Power and Light Company or its representatives.
Central Power and Light Company requests that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this Subpoena, which are found tcgether in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian:
(e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or con #i hntia.1 nature of any such document.
" Doe:uments" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communcations, 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.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
RETURN ON SERVICE Received this subpoena at .......................... on
............... and on ............... at ...............
..................... served it on the within named ..........
.............. . .. by delivering a copy to h.... and ten-dering to h ... the fee for one day's attendance and the mileage allowed by law.
Dated ... .......... 19.... By.........................
Service Fees Travel ..................$
Services ................$
Total ...................$
Subscribed and sworn to before me, a ................ ......
this .... day of................, 19....
O i