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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ST-HL-AE-4162, Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses1992-07-22022 July 1992 Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses ST-HL-AE-4146, Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants1992-07-0606 July 1992 Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants ST-HL-AE-4145, Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule1992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule ML20101K1131992-06-29029 June 1992 Motion for Leave to Suppl Motion to Modify or Quash Subpoenas & Supplemental Info.* OI Policy Unfair & Violative of Subpoenaed Individuals Statutory Rights & Goes Beyond Investigatory Authority.W/Certificate of Svc ML20101G2041992-06-18018 June 1992 Motion to Modify or Quash Subpoenas.* Requests Mod of Subpoenas Due to Manner in Which Ofc of Investigations Seeks to Enforce Is Unreasonable & Fails to Protect Statutory Rights of Subpoenaed Individuals.W/Certificate of Svc ML20087L3301992-04-0202 April 1992 Affidavit of RW Cink Re Speakout Program ML20087L3491992-04-0202 April 1992 Affidavit of JW Hinson Re ATI Career Training Ctr ML20087L3651992-04-0202 April 1992 Affidavit of Rl Balcom Re Access Authorization Program ML20087L3561992-04-0202 April 1992 Affidavit of Wj Jump Re Tj Saporito 2.206 Petition ML20116F2671992-02-19019 February 1992 Requests NRC to Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility ML20094E9511992-02-10010 February 1992 Requests That NRC Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility & to Adequately Train All Util Employees in Use of Rev 3 to Work Process Program ML20066C5041990-09-24024 September 1990 Comment on Proposed Rule 10CFR26 Re NRC Fitness for Duty Program.Urges NRC Examine Rept Filed by Bay City,Tx Woman Who Was Fired from Clerical Position at Nuclear Power Plant Due to Faulty Drug Test Administered by Util ML20006A0281990-01-0808 January 1990 J Corder Response to NRC Staff Motion to Modify Subpoena & Motion for Protective Order.* Requests Protective Order Until NRC Makes Documents Available to Corder by FOIA or Directly.W/Certificate of Svc ML20005G1431989-12-11011 December 1989 Motion to Modify Subpoena & Motion for Protective Order.* Protective Order Requested on Basis That Subpoena Will Impose Undue Financial Hardship on J Corder ML20005G1451989-12-0505 December 1989 Affidavit of Financial Hardship.* Requests NRC to Provide Funds for Investigation & Correction of Errors at Plant Due to Listed Reasons,Including Corder State of Tx Unemployment Compensation Defunct ST-HL-AE-3164, Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components1989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20205T7001988-11-0101 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Initiation of Fitness for Duty Program at Facility.Need for Program Based on Presumption That Nuclear Power Activities Require That Personnel Be Free from Impairment of Illegal Drugs ML20151M2071988-07-25025 July 1988 Comment Supporting Proposed Rules 10CFR170 & 171 Re Fee Schedules.Principal Objection to Rules Relates to Removal of Current Ceilings on Collection of Fees ML20196A3701988-06-17017 June 1988 Notice of Receipt of Petition for Director'S Decision Under 10CFR2.206 & Issuance of Director'S Decision Denying Petitioners Request DD-88-09, Decision DD-88-09 Denying 880317 Petition by Earth First, Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign & Travis County Democratic Women Committee for Commission to Delay Util Licensing Vote1988-06-17017 June 1988 Decision DD-88-09 Denying 880317 Petition by Earth First, Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign & Travis County Democratic Women Committee for Commission to Delay Util Licensing Vote ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20150D1401988-03-21021 March 1988 Appeal of Director'S Decision on Southern Texas Project.* Requests That Commission Consider Appeal & Stay Licensing Decision Until Sufficient Evidence Acquired to Support Final Decision ML20150D0411988-03-17017 March 1988 Petition Of:Earth First!,Gray Panthers of Austin,Lone Star Green,Public Citizen,South Texas Cancellation Campaign, Travis County Democratic Women'S Committee.* Withholding of Issuance of License Requested ML20196H4661988-02-29029 February 1988 Receipt of Petition for Director'S Decision Under 10CFR2.206.* Gap 880126 Petition to Delay Voting on Full Power OL for Facility Until Investigation of All Allegations Completed Being Treated,Per 10CFR2.206 ML20148Q9531988-01-26026 January 1988 Petition of Gap.* Commission Should Delay Vote on Licensing of Facility Until Thorough Investigation of All Allegations Completed & Public Rept Issued.Exhibits Encl ML20237C2751987-12-13013 December 1987 Director'S Decision 87-20 Denying Petitioners 870529 Motion That Record in Facility Licensing Hearings Be Reopened & Fuel Loading Be Suspended Pending Resolution of Issues. Petitioner Failed to Provide Any New Evidence ML20236H3751987-10-29029 October 1987 NRC Staff Consent to Motion to Quash Subpoena Filed by E Stites.* Staff Concedes Possibility of Deficiencies in Svc of Subpoena to Stites & Therefore Does Not Oppose Motion to Quash.Certificate of Svc Encl ML20236E0111987-10-23023 October 1987 Order.* Grants NRC Request for Addl Time to Respond to Motion to Quash Subpoena of E Stites,Per 871008 Order. Response Should Be Filed by 871029.Served on 871023 ML20235T3891987-10-0808 October 1987 Motion to Quash Subpoena & Motion for Protective Order.* Subpoena Issued by Rd Martin on 870922 Should Be Quashed Due to Stites Not Properly Served,Witness Fees & Transportation Costs Not Provided & Issuance in Bad Faith ML20235T4171987-10-0808 October 1987 Memorandum in Support of Motion to Quash or in Alternative in Support of Motion for Protective Order.* Martin 870922 Subpoena of Stites Invalid & Improper.Decision to Subpoena at Late Date Form of Harassment.W/Certificate of Svc ML20195D8561987-09-22022 September 1987 Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant IA-87-745, Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant1987-09-22022 September 1987 Subpoena Directing E Stites to Appear on 871008 in Arlington,Tx to Testify Before NRC Personnel Re Allegations Made Concerning safety-related Deficiencies &/Or Records Falsifications at Plant 1999-05-04
[Table view] Category:PLEADINGS
MONTHYEARML20101K1131992-06-29029 June 1992 Motion for Leave to Suppl Motion to Modify or Quash Subpoenas & Supplemental Info.* OI Policy Unfair & Violative of Subpoenaed Individuals Statutory Rights & Goes Beyond Investigatory Authority.W/Certificate of Svc ML20101G2041992-06-18018 June 1992 Motion to Modify or Quash Subpoenas.* Requests Mod of Subpoenas Due to Manner in Which Ofc of Investigations Seeks to Enforce Is Unreasonable & Fails to Protect Statutory Rights of Subpoenaed Individuals.W/Certificate of Svc ML20116F2671992-02-19019 February 1992 Requests NRC to Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility ML20094E9511992-02-10010 February 1992 Requests That NRC Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility & to Adequately Train All Util Employees in Use of Rev 3 to Work Process Program ML20006A0281990-01-0808 January 1990 J Corder Response to NRC Staff Motion to Modify Subpoena & Motion for Protective Order.* Requests Protective Order Until NRC Makes Documents Available to Corder by FOIA or Directly.W/Certificate of Svc ML20005G1431989-12-11011 December 1989 Motion to Modify Subpoena & Motion for Protective Order.* Protective Order Requested on Basis That Subpoena Will Impose Undue Financial Hardship on J Corder ML20150D1401988-03-21021 March 1988 Appeal of Director'S Decision on Southern Texas Project.* Requests That Commission Consider Appeal & Stay Licensing Decision Until Sufficient Evidence Acquired to Support Final Decision ML20148Q9531988-01-26026 January 1988 Petition of Gap.* Commission Should Delay Vote on Licensing of Facility Until Thorough Investigation of All Allegations Completed & Public Rept Issued.Exhibits Encl ML20236H3751987-10-29029 October 1987 NRC Staff Consent to Motion to Quash Subpoena Filed by E Stites.* Staff Concedes Possibility of Deficiencies in Svc of Subpoena to Stites & Therefore Does Not Oppose Motion to Quash.Certificate of Svc Encl ML20235T3891987-10-0808 October 1987 Motion to Quash Subpoena & Motion for Protective Order.* Subpoena Issued by Rd Martin on 870922 Should Be Quashed Due to Stites Not Properly Served,Witness Fees & Transportation Costs Not Provided & Issuance in Bad Faith ML20235T4171987-10-0808 October 1987 Memorandum in Support of Motion to Quash or in Alternative in Support of Motion for Protective Order.* Martin 870922 Subpoena of Stites Invalid & Improper.Decision to Subpoena at Late Date Form of Harassment.W/Certificate of Svc ML20216D1111987-06-25025 June 1987 Reply of Bp Garde to NRC Staff Opposition to Motion to Quash & De Facto Opposition to Petition Per 10CFR2.206.* NRC Has Not Established That Garde Assertions Not Sustainable.Certificate of Svc Encl ML20215D6471987-06-11011 June 1987 NRC Staff Answer Opposing Motion to Quash Subpoena Filed by Bp Garde,Esquire.* Gap Has Not Provided Sufficient Basis on Which Commission Could Conclude That attorney-client Privilege Protects Info Sought by Nrc.W/Certificate of Svc ML20214P3101987-05-29029 May 1987 Petition of Gap.* Requests That NRC Initiate Special Investigative Unit Complying W/Nrc Chapter Manual 0517, Excluding Region IV & V Stello from Participation,To Investigate Employee Allegations.Supporting Matl Encl ML20237G5981987-05-29029 May 1987 Motion to Reopen Record of Licensing Hearing to Determine Whether ASLB Conclusions Should Be Altered Due to Evidence of Undue Influence Exercised Over NRC Personnel by Util Mgt. Related Documentation Encl ML20214P2851987-05-29029 May 1987 Motion & Memo to Quash Subpoena.* Bp Garde Motion That Commission Quash V Stello 870520 Subpoena ML20203E1851986-07-22022 July 1986 Motion for Leave to File Supplemental Affidavit of Jn Wilson Re Design of Nonconforming Structures to Withstand Hurricanes & Tornados in Order to Correct Erroneous Statements Made in 860714 Affidavit.Related Correspondence ML20207E1131986-07-17017 July 1986 Statement of Views on Questions Re Design of Nonconforming Structures to Withstand Hurricanes & Tornadoes.W/Certificate of Svc.Related Correspondence ML20210E2071986-03-21021 March 1986 Motion to Compel Production of Documents Re Alleged Illegal Drug Use in Response to Applicant 860306 Response to Second Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20154Q1391986-03-19019 March 1986 Response Opposing Citizens Concerned About Nuclear Power, Inc 860228 Motion to Reopen Phase II Record:V & for Board Ordered Production of Documents.Motion Not Timely Filed. Certificate of Svc Encl ML20154Q3341986-03-19019 March 1986 Response Supporting Applicant Motion for Leave to Reply to Portions of Citizens Concerned About Nuclear Power,Inc Partial Response to Show Cause Order.Certificate of Svc Encl.Related Correspondence ML20138B0161986-03-17017 March 1986 Response to Citizens Concerned About Nuclear Power,Inc 860228 Motion to Compel Further Answers to Second Set of Interrogatories.Disclosure of Info Constitutes Invasion of Employee Privacy.Certificate of Svc Encl ML20138A8781986-03-14014 March 1986 Response Opposing Citizens Concerned About Nuclear Power,Inc 860221 Motion to Reopen Phase II Record.Affidavit of JW Briskin Encl ML20141N8461986-03-12012 March 1986 Motion for Summary Disposition of Issue F.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision.Affidavit of Je Geiger Encl ML20154B6111986-02-28028 February 1986 Response Opposing Portions of Concerned Citizen About Nuclear Power 860221 Partial Response to ASLB 860207 Show Cause Order.Further Arguments on Motion to Reopen Should Be Rejected.W/Certificate of Svc ML20154B4791986-02-28028 February 1986 Response Opposing Applicant 860218 Motion for Protective Order,Instructing Applicant Not to Answer 860204 Second Set of Interrogatories & Request for Production of Documents. W/Certificate of Svc.Related Correspondence ML20154B5781986-02-28028 February 1986 Motion for Leave to Reply to Portions of Concerned Citizen About Nuclear Power 860221 Partial Response to ASLB 860207 Show Cause Order.Proposed Reply Encl ML20154B8471986-02-28028 February 1986 Motion to Compel Applicant Response to Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20205K6151986-02-21021 February 1986 NRC Position in Response to ASLB 860207 Memorandum & Order Requesting Addl Info to Resolve Citizens Concerned About Nuclear Power,Inc Motion to Reopen Phase II Record:Iv. Certificate of Svc Encl ML20141N2131986-02-21021 February 1986 Motion to Reopen Phase II Record to Admit Encl Deposition of JW Briskin,For Order to Produce Documentation Re Quadrex Corp & to Schedule Hearings at Conclusion of Ordered Production of Documents.Certificate of Svc Encl ML20137W8841986-02-18018 February 1986 Motion for Protective Order to Direct Util to Respond to Only Interrogatories 12a,b & C in Citizens Concerned About Nuclear Power 860204 Second Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20151T7131986-02-0606 February 1986 Response Supporting Citizens Concerned About Nuclear Power, Inc 860117 Motion to Withdraw Contention Re Overpressurization of Westinghouse Reactors.Certificate of Svc Encl ML20151T6861986-02-0606 February 1986 Response Opposing Citizens Concerned About Nuclear Power,Inc 860117 Motion to Reopen Phase II Record for Discovery & to Suspend Further Activity in Phase III ML20151U6731986-02-0303 February 1986 Response to Citizens Concerned About Nuclear Power,Inc 860117 Motion to Reopen Phase II Record.Motion Supported to Include Addl Discovery & Hearings.Discovery Previously Limited by Board Contentions 9 & 10.W/Certificate of Svc ML20151T5841986-02-0303 February 1986 Response Opposing Citizens Concerned About Nuclear Power 860117 Motion to Reopen Phase II Record:Iv;For Discovery & to Suspend Further Phase III Activity.Util Withholding Quadrex Rept W/Intent to Deceive ASLB ML20198H2791986-01-29029 January 1986 Response Supporting Applicant 860109 Motion to Incorporate Corrections Into 851205 & 06 Transcripts.Certificate of Svc Encl ML20137J0971986-01-17017 January 1986 Motion to Reopen Phase II Record:Motion IV for Discovery & to Suspend Further Activity in Phase Iii.Encl EA Saltarelli Oral Deposition & Overview of Facility Engineering Should Be Entered Into Phase Ii.Related Correspondence ML20140B6191986-01-17017 January 1986 Motion for Withdrawal of Contention Re Overpressurization of Westinghouse Reactors.Certificate of Svc Encl ML20137A8731986-01-0909 January 1986 Motion to Incorporate Proposed Corrections to Transcript of 851205-06 Hearing ML20151T5291986-01-0303 January 1986 Response Supporting Citizens Concerned About Nuclear Power 860114 Motion to Withdraw Pending Contention on Overpressurization of Westinghouse Reactors.Certificate of Svc Encl ML20137L9501985-11-27027 November 1985 Motion to Sequester Witnesses to Be Called in Reopened Phase II Hearings on 851205 & 06 Re Issues of Credibility. Certificate of Svc Encl.Related Correspondence ML20210A4581985-11-13013 November 1985 Response Supporting Applicant 851014 Motion to Establish Schedule for Phase III of Proceeding.Certificate of Svc Encl ML20205G5251985-11-0808 November 1985 Response to Applicant 851014 Motion to Establish Schedule for Phase III Hearings.Proceeding Activities Re Phase III Should Be Suspended Until After Issuance of Partial Initial Decision Phase Ii.Certificate of Svc Encl ML20198B7991985-11-0505 November 1985 Motion Opposing Intervenor 851016 Motions to Reopen Phase II Record.Stds for Reopening Record Not Met.Certificate of Svc Encl ML20198B8431985-11-0404 November 1985 Motion to Strike Reckless Charges in 851029 Withdrawal Motion from Record.Intervenor Should Be Warned That Repetition of Behavior Will Not Be Tolerated.Certificate of Svc Encl ML20138N2431985-10-31031 October 1985 Response Opposing Citizens Concerned About Nuclear Power Motion to Reopen Phase II Record:Ii.Exhibits 2 & 4 Barren of Any Info on Quadrex Review or Results.W/Certificate of Svc ML20138N0291985-10-29029 October 1985 Motion to Withdraw 851016 Motion to Reopen Phase II Record & for Discovery.Certificate of Svc Encl ML20138H9981985-10-24024 October 1985 Response to Applicant 851004 Motion to Incorporate Transcript Corrections.Offers No Objection Except for Listed Proposed Changes.Certificate of Svc Encl ML20133J1521985-10-16016 October 1985 Motion to Reopen Phase II Record to Admit Four Encl Exhibits.Certificate of Svc Encl ML20133J3501985-10-16016 October 1985 Motion to Reopen Phase II Record & Extend Right to Discovery Set Forth in ASLB 850618 Memorandam & Order to All Parties. Certificate of Svc Encl 1992-06-29
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~, .
e EC PLII TC ET CU?2}IT _m C?.i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOrI BEFORE THE ATCMIC SAFETY AND LICENSI!:C BOARS ,- 4M 5
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- [A ya 0
V-MS.l 1 ;3l'_ >V/GJ
. . ,,. . , m In the Matter of : $ 3.a ,
fp HOUSTON LIGHTING IsND POWER COMPANY : b a U'
THE CITY OF SAN ANTONIO :
THE CITY OF AUSTIN AND : Docket Nos. 50-498A CENTRAL POWER AND : 50-499A LIGHTING COMPANY :
(South Texas Project, Units t!os. :
1 and 2). :
JOINT MOTION FOR WITHDRAWAL OF SUBPOEt:AS AND FOR WITHDRAWAL OF MOTIOt!S Communications with respect to this document should be addressed to the following:
Jonathan Day, Esq. Thomas G. Ryan, Esq.
BUTLER, BINION, RICE, COOK ISHAM, LINCOLN & BEALE
& KNAPP One First :ational Plaza 1100 Esperson Building Suite 4300 Hcuston, Texas 77002 Chicago, Illinois 60603 Robert E. Cohn, Esq. IS HI.M , LINCOLN & BEALE Richard J. Le idl, Esq. 1050 17th Street, N.W.
BUTLER, BINION, RICE, COOK Seventh Floor
& KNAPP Washington, D.C. 20036 818 Connecticut Avenue, N.W.
Washington, D.C. 20019 Attorneys for Central Power and Light Attorneys for Company Air Products and Chemicals, Inc.
E.I. DuPont de Nemours & Co. Marc Poirier, Esq.
Monsanto Company SPIEGEL & MCDIARMID PPG Industries, Inc. 2600 Virginia Avenue, N.W.
Union Carbide Corporation Washington, D. C. 20037 Attorneys for The Public Utilities Board of the City of Brownsville, Texas March 1, 1979 7903140G G
UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMllISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAF.D In the Matter of :
HOUSTON LIGHTING AND POWER COMPANY :
THE CITY OF SAN ANTONIO :
THE CITY OF AUSTIN AND CENTRAL PCHER AND : Docket Nos. 50-49SA LIGHTING CCMPANY : Nos. SG-499A (South Texas Project, Units Mos. :
1 and 2). :
JOINT MOTION FOR WITHDRAWAL OF SUBPOENAS AND FCR WITHDRAMAL OF IIOTIONS Central Power and Lignt Company (CPL) hereby moves (1) to withdraw its application dated January 18, 1979 to the Atomic Safety and Licensing Board for the issuance to Air Products and Chemicals, Inc., E. I. DuPont de Nemours & Co.,
Monsanto Company, PPG Incustries, Inc. and Union Carbice Corporation (each referred to as a " Company" and collectively as the " Companies") of related subpoenas for the production of documents and for depositions and (2) to withdraw the subpoenas issued pursuant to such application.
The Public Utilities Board of the City of Brownsville, Texas (Brownsville) hereby moves (1) to withdraw its application dated February 22, 1979 to the Atomic Safety and Licensing Ecard for the issuance of a subpoena for the deposition of Mr. Robert L.
Wright of Union Carbide Corporation, (2) to withdrau the subpoena
. .- issued pursuant to such application and (3) to withdraw its motion dated February 23, 1979 in opposition to the motion of the Companies to quash the subpoenas issued on the application of CPL.
The Companies hereby jointly move to withdraw the joint motion dated February 16, 1979 to quash the related subpoenas for the production of documents and for depositions issued by the Atomic Safety and Licensing Board on January 31, 1979 on the application of CPL. -1/
In consideration of the foregoing, the joint movants herein have agreed as follows:
(1) The Companies will make available Messrs. Edward V.
Sherry, A.D. Cyphers, Lee C. Peeler, Robert H. Steder and Robert L. Wright for deposition at the times and places designated in Exhibit A attached hereto; (2) The depositions shall be limited to inquiries concerning the areas covered by the documents listed below, which documents shall be produced by the Companies prior to the taking of the depositions:
A. All documents which relate to the testimony given by the deponent before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings).
B. Documents suf ficient to show the typical considera-tion accorded electric utility rates, costs, reliability of service or availability of service in a plant or facility siting or locational decision of the Company.
1/ The Companies will not withdraw the motion to quash unless the subpoenas of CPL and Brownsville are con-currently withdrawn.
C. Examples of documents which show, describe or relate to 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.
D. Best efforts to obtain documents since January 1, 1976 which show, describe or relate to attempts on the part of any electric utility operating, in whole or in part, in Texas to provide new or expanded electric service to prospective or current plants or facilities of the Company.
(3) Compliance by the Companies with this agreement is subject to the prior issuance of an order by the Nuclear Regulatory Commission or the Atomic Safety and License Board granting a motion of the Companies filed on March 1, 1979 for a protective order, in substantially the form attached as Exhibit A to that motion, regarding the afore-mentioned depositions and production of documents.
Since the grant of this motion and the issuance of a pro-tective order are preconditions to the disclosure of documents and the taking of depositions, the movants urge expeditious consideration of this motion.
_4_
WHEREFORE, the movants respectfully request (1) the withdrawal of the applications of CPL for subpoenas and the 2/
subpoenas themselves, (2) the withdrawal of the application 3/
of Brownsville for a subpoena and the subpoena itself,-(3) the withdrawal of the motion of Brownsville in opposition to the motion of the Companies to quash, and (4) the withdrawal of the joint motion of the Companies to quash subpoenas.
Respectfully submitted,
/ /
/f)Os YW fobeUt~ C. Uo h n' c$& 0.
Ridhard J.
MAP Le id l' BUTLER, BINICN, RICE, CCOK
& KNAPP Attorneys for Air Products and Chemicals, Inc.
E. I. DuPont de Nemours & Co.
Monsanto Company PPG Industries, Inc.
Union Carbide Corporation 2/ CPL reserves the right to reapply for the issuance of subpoenas if the Companies' responses are not satis-factory.
3/ Brownsville reserves the right to reapply for the issuance of the subpoena if the response of the Company is not satisfactory.
)e >
. < - v- i . ; -)
J 3Ii M-i , LINCOL:' L BCALS Attorney', for Central Pow er and Ligh t Con.t:a n.v.
l /, ,
n l l- * / ~' y:.,c' a
s SPfICCL & .J:DI A RNI O Attorneys tor the Public Uttiition Doard af the Ci ty o C- Brownsville , Te x a '-
D .i t e d : I: arch 1, 1979
Exhibit A Docket Nos. 50-498A 5' 199A List of time and place of taking of depositions Central Power and Light Company Edward V. Sherry March 22, 1979 at 9:30 a.m.
Holiday Inn Route 22 at Junction of Route 309 Allentown, Pennsylvania A.D. Cyphers March 15, 1979 at 9:30 a.m.
Holiday Inn 2705 East Houston Victoria, Texas Lee C. Peeler March 14, 1979 at 9:30 a.m.
Holiday Inn Junction of Highway 6 and 35 Alvin, Texas Robert H. Steder March 23, 1979 at 9:30 a.m.
William Penn Hotel P.O. Box 1978 Mellon Square Pittsburgh, Pennsylvania Robert L. Wright March 16, 1979 at 9:30 a.m.
Best Western Shellfish Inn Highway 35 North Box 227 Port Lavaca, Texas Public Utilities Board of the City of Brownsville, Texas Robert L. Wright March 16, 1979 at 9:30 a.m.
Best Western Shellfish Inn Highway 35 North Box 227 Port Lavaca, Texas
CERTIFICATE OF SEAVICE I hereby certify that I have this day servec a copy of the foregoing Joint I:otion for Withdrasial of Subpoencs and for Withdrawal ot lotions on all parties set forth in the attached list by first-class mail, postatje prepaid, f
liA!/ // $
II6Ee rt E. ' Cohn
'}f -
Counsel for Air Products and Chemicals, Inc.
C. I. DuPont de Nemours & Co.
Monsanto Company PPG Industries, Inc.
Union Carbide Corporation March 1, 1979
- Lchard S. Salzman, Esquire R. Bruce Whitney, Esq.
- .S. Nuclear Regulatory 20mmission Air Products and Chemicals, Inc.
.,ashington, D.C. 20555 P.O. Box 538 Allentown, Pennsylvania 18105 Jerome E. Sharfman, Esquire U.S. Nuclear. Regulatory Commission Paul M. King, Esq.
!ashington, D.C. 20555 PPG Industries, Inc.
One Gateway Center Pittsburgh, Pennsylvania 15222 Thomas G. Ryan, Esq. Ross Austin, Esq.
tuham, Lincoln & Beale E. I. DuPont de Nemours & Co.
Jae First National Plaza Wilmington, Delaware 19890 Juite 4300 2hicago, Illinois 60603 John Stapleton, Esq. R. Gordon Gooch, Esq.
'tonsanto Company John P. Mathis, Esq.
300 N. Lindbergh Baker & Botts 3t. Louis, Missouri 63166 1701 Pennsylvania Ave., M.W.
Washington, D.C. 20006 Stanley Baumblatt, Esq.
Union Carbide Corporation Roy P. Lessy, Jr., Esq.
270 Park Avenue Micahel B. Blume, Esq.
New York, NY 10017 U.S. Nuclear Regulatory Commission Washington, DC 20555 e
1 Roff Hardy Don R. Butler, Esq.
Chairman and Chief Executive Sneed, Vine, Wilkerson, Officer Selman & Perry .
Central Power & Light Company P.O. Box 1409 P.O. Box 2121 Austin, TX 78767 ,
Corpus Christi, TX 78403 Mr. Perry G. Brittain President Jerry L. Harris, Esq.
Texas Utilities Generating Richard C. Balough, Esq.
Company City of Austin 2001 Bryan Tower P.O. Box 1088 Dallas, TX 75201 Austin, TX 73767 R.L. Hancock, Director Don H. Davidson City of Austin Electric Utility City Manager P.O. Box 1086 City of Austin Austin, TX 78767 P.O. Box 1088 Austin, TX 78767 G.W. Oprea, Jr. Robert Lowenstein Executive Vice President J. A. Bouknight, Jr.
Houston Lighting & Power Company William J. Franklin P.O. Box 1700 Lowenstein, Newman, Reis &
Houston, TX 77001 Axelrad 1025 Connecticut Ave., N.W.
Washington, DC 20036 John W. Davidson, Esq.
Judith Harris, Esq. Sawtelle, Goode, Davidson &
Ronald Clark, Esq. Tioilo U.S. Department of Justice 1100 San Antonio Savings Bldg.
Antitrust Division San Antonio, TX 18205 411 - llth St. , N.W. ,
Washington, DC 20530 .
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Douglas F. John, Esq. Joseph Rutberg, Esq.
Akin, Gump, Haver & Feld Antitrust Counsel 1100 Madison Office Bldg. Counsel for NRC Staff 1155 15th Street, N.W. '
U.S. Nuclear Regulatory.
Washington, DC 20005 Comtission Washington, DC 20555 Morgan Hunter, Esq. Joseph J. Saunders, Esq.
Bill D. S t. Clair, Esq. Chief, Public Counsel &
McGinnis, Lockridge & Legislative Section Kilgore Antitrust Section Fifth Floor,' Texas State Bank Bldg. U.S. Department of Justice 900 Congress Avenue P.O. Box 14141 Austin, TX 78701 Washington, D.C. 20044 Kevin B. Pratt Texas Attorney General's Office G.K. Spruce, General Manager State of Texas City Public Service Board P.O. Box 12548 P.O. Box 1771 Austin, TX 78711 San Antonio, TX 78203 U.S. Robson William H. Burchett, Esq.
General Manager Frederick H. Ritts, Esq.
South Texas Electric Cooperating, Northcutt Ely Inc. Watergate 600 Building Route 6, Building 102 Washington, DC 20037 Victoria Regional Airport Victoria, TX 77901 Joseph B. Knotts, Jr. Robert C. McDiarmid, Esq.
Nicholas S. Reynolds Robert Jablon, Esq.
Debevoice & Liberman 2600 Virginia Avenue, N.W.
806 15th Street, N.W. Washington, DC 20037 Suite 700 Washington, DC 20005
Marshall E. Miller, Esq. Mr. Jerome D. Saltzman U.S. Muclear Regulatory Commission Chief, Antitrust and Washington, D.C. 20555 Indemnity Group U.S. Nuclear Regulatory Commission Nuclear Reactor Regulation Washington, D.C. 20555 Michael L. Glaser, Esq. J. Irion Worsham, Esq.
1150 17th Street, N.W. Merlyn D. Sampels, Esq.
Washington, D.C. 20036 Spencer C. Relyea, Esq.
Worsham, Forsythe & Sampels 2001 Bryan Tauer, Suite 2500 Dallas, TX 75201 Jon C. Wood, Esq.
Sheldon J. Wolfe, Esq. W. Roger Wilson, Esq.
U.S. Nuclear Regulatory Commission Matthews, Nowlin, Macfarlane Washington, D.C. 20555 & Barrett 1500 Alamo National Building San Antonio, TX 78205 Atomic Safety and Licensing Charles G. Thrash, Jr., Esq.
Appeal Board Panel E.W. Barnett, Esq.
U.S. Muclear Regulatory Commission Theodore F. Weiss, Esq.
Washington , D.C. 20555 J. Gregory Copeland, Esq.
Baker & Botts 3000 One Shell Plaza Houston, TX 77002 HAND DELIVERED Chase R. Stephens Samuel J. Chilk, Secretary Docketing and Service Branch office of the Secretary of the U.S. Nuclear Regulatory Commission Commission
Richard D. Cudahy, Esq. John E. Mathews, Jr., Esq.
Robert H. Loeffler, Esq.
Mathews, Osborne, Ehrlich, McNatt Joseph Gallo, Esq. Gobelman & Cobb Isham, Lincoln & Beale 1500 American Heritage Life Bldg.
1050 17th Street, N.W. Jacksonville, Florida 32202 Seventh Floor Washington, DC 20036 Wheatley & Miller Robert E. Bathen 1112 Watergate Office Bldg. R.W. Beck & Associates 2600 Virginia Ave. N.W. P.O. Box 6817 Washington, DC 20037 Orlando, Florida 82853 Linda L. Aaker, Esq.
Assistant Attorney General P.O. Box 12548 Capital Station Austin, TX 78711 Knoland J. Plucknett Executive Director Committee on Power for the Southwest, Inc.
5541 E. Skelly Dr.
Tulsa, Oklahoma 74135 Jay M. Galt, Esq.
Looney, Michol:_, Johnson & Hayes 219 Couch Drive Oklahoma City, Oklahoma 73101 O