ML19296B516
| ML19296B516 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 02/05/1980 |
| From: | Franklin W BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | |
| References | |
| NUDOCS 8002200739 | |
| Download: ML19296B516 (55) | |
Text
UNITED STATES OF AMERICA
^
NUCLEAR REGULATORY CO3HISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project, Units 1
)
and 2)
)
)
TEXAS UTILITIES GENERATING COMPANY)
Docket Nos. 50-445A et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
APPLICATION POR ISSUANCE OF SUBPOENAS Houston Lighting and Power Company, pursuant to 10 C.F.R.
SS2.740, and 2.741, apolics for the issuance of the attached Subpoenas, which calls for a deposition reauiring the attendance of the party listed, and for production of documents.
The document production sought encompasses, but is not limited to, the testimony to be given in the instant proceeding, interest in and awareness of nuclear power projects, interconnections and operations involving interstate systems and the Texas Interconnected Systems, bulk electric power supply, transmission planning, and fuel supply for electrical generation of electricity.
Subpoena (1)
George C.
Campbell, City of Weatherford (2)
Morris Howard, City of Commerce (3)
Elton McGinnis, Southwest Texas Electric Cooperative (4)
Val Robertson, City of Hearne 8002 200 M M
=
(5)
Parker Wetzel, Midwest Electric C9 operative (6)
John McKelvey, Esquire (7)
R.A.
Yarbrough Respectfully submitted,
&'wN sef William J.
Franklin Attorney for Houston Lighting &
Power Comoany OF COUNSEL:
BAKER & BOTTS 3000 One Shell Plaza llouston, Texas 77002 Lowenstein, Newman, Reis, Axelrad
& Toll 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Dated:
February 5, 1980
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
IlOUSTON LIGilTING & POWER COMPANY,
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOENA TO: John McKelvey, Esquire 109 North Main Street P.O.
Box 391 Electra, Texas 76360 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the In the City of. Wichita Falls, IIoliday Inn, 8th and Scott Streets, day of. February,1980 Texas 28th on the 9:30 A.M.
at (and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required to the testimony you may give in the trial of this action, all as matters relating thereto, and all subject matters covered in the O
4 _
attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19.
Douglas G.
Green Attorney for Houston Lighting
& Power Company LOWENSTEIM, NEMMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 862-8400 10 C.F.R. 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Contpany and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between City of Electra, its agents, or employees and any of the afore-mentioned entities.
2.
All documents provided to or received from the U.S. Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-ceeding, or the licensing of any nuclear powered electric generation plant.
All documents referring or relating to or setting forth meet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S.
Department of Justice or U.S. Nuclear Regulatory Commission.
3.
All documents provided to or received from an attorney for or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any.other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting forth meetings or conversations with any of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nuclear powered electric generating plant by any electric utility, municipal system, electrical cooperative, or com-bination thereof.
5.
All documents referring or relating to or setting forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
~
7.
All documents referring or relating to or setting forth each bulk power su" ply plan prepared by or for the City of Electra since January 1, 1973.
8.
All documents referring or relating to or setting forth each transmission study developed by or for the City of Electra in connection with any of the bulk power supply plans covered in item number 7 above.
9.
All documents referring or relating' to or setting forth corre-spondence or contracts between the City of Electra and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
10.
All documents referring or relating to or setting forth any correspondence or contracts between the City of Electra and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection, and copying by Houston Lighting & Power Company or its representatives.
Houston Lighting & Power Company requests'that the Keeper of the Records identify the specific reauest or reauests to which each document is responsive.
Where possible, the Keeper of the Records is requested to maintain the intecrity of it.s 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 loc 4 tion and custodian:
(c) 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 unavailaole) 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, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar or diary entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions -
of any of the foragoing and any supporting, underlying or preparatory material.
RETURN ON SERVICE Received this subpoena at............................on
...................and on
................at..........
................... served it on the within names.......
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Total.....................$
Subscribed and sworn to before me, a..................
this......... day of...............,19.....
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.01ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY,
)
Do'cket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOENA TO:
Parker Wetzel Midwest Electric Coop P.O. Box 518 Roby, Texas 79543 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the (2500) Bryan 'Ibwer, 2001 Bryan Street.2n the City of. Dallas, day of. February,1980 22nd
'.Ibxas on the 9:00 A.M.
at (and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the
attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19 Douglas G.' Green Attorney for Houston Lighting
& Power Company LOWENSTEIN, NEWMAN, REIF, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
2003C (202) 862-8400 10 C.F.R. 2.720(f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOEUA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Company and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between Midwest Electric Coop, its agents, or employees and any of the aforementioned entities.
2.
All documents provided to or received from the U.S. Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-cceding, or the licensing of any nuclear powered electric generation plant.
All documents referring or relating to or setting forth meet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S.
Department of Justice or U.S.
Nuclear Regulatory Commission.
3.
All documents provided to or received from an attorney for or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H. Guernsey Corporation; (Ci Central and Southwest Corporation and/or any of its subsidiaries ins luding without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting forth meetings or conversations with any
~
of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nuclear powered electric generating plant by any electric utility, municipal system, electrical cooperative, or com-bination thereof.
5.
All documents referring or relating to or setting forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
7.
All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Midwest Electric Coop since January 1, 1973.
8.
All documents referring or relating to or setting forth each transmission study developed by or for the Midwest Electric Qoop in connection with any of the bulk power supply plans coverei in item number 7 above.
9.
All documents referring or relating'to or setting forth corre-spondence or contracts between Midwest Electric Coop and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
10.
All documents referring or relating to or setting forth any correspondence or contracts between Midwest Electric Coop and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection' and copying by Houston Lighting & Power Company or its representatives.
Houston Lightin, & Power Company requests that the Keeper of the Records identify the specific reauest or reauests to which each document is responsive.
Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeenina 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, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calencar or diary entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions -
of any of the foregoing and any supporting, underlying or preparatory material.
RETURN ON SERVICE Received this subpoena at............................on
...................and on
.................at..........
................... served it on the withi n names.......
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Total.....................$
Subscribed and sworn to before me, a..................
this......... day of...............,19.....
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY,
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOENA TO:
George C.
Campbell City Manager City of Weatherford 119 Palopinto Street Weatherford, Texas 76086 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the (2500)
UU."". M#
2001 Bryan, Street. in the City of Dal,las,
Ms on the 19th day of. Fqbryafy,,1,980 9 OO,A;M.
(and thereafter from day to day, if necessary) to i
at testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required as to the testimony you may give in the tria3 of this action, all matters relating thereto, and all subject matters covered in the
attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19 Douglas G.
Green Attorney for Houston Lighting
& Power Conpany LOWENSTEIN, NENMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 862-8400 10 C.F.R.
- 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Coppany and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between City of Weatherford, its agents, or employees and any of the aforementioned entities.
2.
All documents provided to or received from the U.S.
Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-cceding, or the licensing of any nuclear powered electric generation plant.
All documents referring or relating to or setting forth meet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S. Department of Justice or U.S.
Nuclear Regulatory Commission.
3.
All documents provided to or received from an attorney for or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting forth meetings or conversations with any of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nuclear powered electric generating plant by any electric utility, municipal system, electrical cooperative, or com-bination thereof.
5.
All documents referring or relating to or setting forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
. ~
7.
All documents referring or relating to or setting forth each bulk power supply plan prepared by or for City of Weatherford since January 1, 1973.
8.
All documents referring or relating to or setting forth each transmission study developed by or for the City of Weatherford in connection with any of the bulk power supply plans covered in item number 7 above.
9.
All documents referring or relating'to or setting forth corre-spondence or contracts between City of Weatherford and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
10.
All documents referring or relating to or setting forth any correspondence or contracts between the City of Weatherford and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made availabic for inspection and copying by flouston Lighting & Power Company or its representatives.
IIouston Lighting & Power Company requests that the Keeper of the Records identify the specific reauest or requests to which each document is responsive.
Where possible, the Keeper of the Records is requested to maintain the intecrity of its filing and recordkeening 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 graohic matter, however produced or reproduced, whether or not now in existence, however produced or reproduced, whether or not now in existence, of correspondence, te legrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communicati'ns, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar or diary entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
RETURN ON SERVICE Received this subpoena at............................on
...................and on
.................at..........
................... served it on the within names.......
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Tota 1.....................$
Subscribed and sworn to before me, a..................
this......... day of...............,19.....
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO!D1ISSION BEFORE Tile ATOMIC S AFETY AND LICENSING BOARD In the Matter of
)
)
!!OUSTON LIGIITI' ' & POWER COMPANY,
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOENA TO:
R.A. Yarbrough 1311 Avenue J, N.W.
Childress, Texas 79201 (Mailing Address)
P.O. Box 764 Childress, Texas 79201 YOU ARE HEREBY COM'4ANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the IIoliday Inn, 8th and Scott Streets In the City of Wichita. Falls.,.
. day o f. eb.ruary, 1980 Texas 29th F
. on the 9:30 A.M.
at (and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required as t.a the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the 4
attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19 Douglas G.
Green Attorney for Houston Lighting
& Power Company LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 862-8400 10 C.F.R. 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable o'r' requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Company and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between Gate City Electric Coop, its agents, or employees and any of the aforementioned entities.
2.
All documents provided to or received from the U.S. Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-ceeding, or the licensing of any nuclear powered electric generation plant.
All documents referring or relating to or setting forth meet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S. Department of Justice or U.S. Nuclear Regulatory Commission.
3.
All documents provided to or received from an attorney for or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting'forth meetings or conversations with any of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nuclear powered electric generating plant by any electric utility, municipal system, electrical cooperative, or com-bination thereof.
5.
All documents referring or relating to or setting'forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
. 7.
All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Gate City Electric Coop;ince January 1, 1973.
8.
All documents referring or relating to or setting forth each transmission study developed by or for the Gate City Electric Coop in connection with any of the bulk power supply plans covered in item number 7 above.
9.
All documents referring or relating to or setting forth corre-spondence or contracts between Gate City Electric Coop and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
10.
All documents referring or relating to or setting forth any correspondence or contracts between Gate City Electric Coop and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Comoany or its representatives.
Houston Lighting & Power Company requests that the Keeper of the Records identify the specific reauest or requests to which each document is responsive.
Where possibic, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeoing systems by producing tooether documents responsive to this subpoena which are found together in the Keener 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 cooies (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, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar or diery entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
RETURN ON SERVICE Received this subpoena at............................on
...................and on
.................at..........
................... served it on the within names.......
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Total.....................$
Subscribed and sworn to before me, a..................
this......... day of...............,19.....
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY,
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOENA TO:
Morris Howard City Manager City of Commerce 119 Alamo Commerce, Texas 75428 YOU ARE HEREBY COMMANDED, puisuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the
'(2500) in the City of. Dallas, Bryan 'Icwer 2001 Bryan Street 1980 day of. February, Texas 22nd on the 2 :00 P. M.
at (and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the
attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19 Douglas G.
Green Attorney for Houston Lighting
& Power Company LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 062-8400 10 C.F.R.
- 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Coppany and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between City of Commerce, its agents, or employees and any of the afore-mentioned entities.
2.
All documents provid' d to or received from the U.S. Depart-ment of Justice or the U.S. duclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-ceeding, or the licensing of any nuclear powered electric generation plant.
All documents referring or relating to or setting forth meet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S.
Department of Justice or U.S.
Nuclear Regulatory Commission.
3.
All documents provided to or received from an attorney fer or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiarie s including without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting forth meetings or conversations with any
~
of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nucicar powered electric generating plant by
' electric utility, municipal system, electrical cooperative, or com-
.ation thereof.
5.
All documents referring or relating to or setting forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected-Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
~
7.
All documents referring or relating to or setting forth each bulk powe supply plan prepared by or for the City of Commerce since January 1, 1973.
8.
All documents referring or relating to or setting forth each in transmission study developed by or for the City of Commerce '
connection with any of the bulk power supply plans covered in item number 7 above.
9.
All documents referring or relating to or setting forth corre-spondence or contracts between the City of Commerce and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
10.
All documents referring or ralating to or setting forth any correspondence or contracts between the City of Commerce and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or its representatives.
Houston Lighting & Power Company requests that the Keeper of the Records identify the specific reauest or requests to which each document is responsive.
Where possible, the Keeper of the Records is regaested 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; (c) any other description necessary to enable the custodian to locate the particular docr' ant; (f) the basis for the claimed privilege; anu (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 graohic matter, however produced or reproduced, whether or not now in existence, however produced or rcproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar or diary entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
RETURN ON SERVICE Received this subpoena at............................on
...................and on
.................at..........
................... served it on the within names.
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Total.....................$
Subscribed and sworn to before me, a..................
this......... day of...............,19.....
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY,
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOEUA TO:
Val Robertson City Manager City of Hearne 210 Cedar Street Hearne, Texas 77859 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the (2500), Eryan.Ttxgr,. 2p01 Eryan.Stregtin the City of Dalla,s,
. on the
,. day of Feb,ru g, 1980, 20m at ):00 A.M'. (and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the
attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19 Douglas G.
Green Attorney for Houston Lighting
& Power Company LOWENSTEIN, NENMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 862-3400 10 C.F.R.
- 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Company and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between City of Hearne, its agents, or employees and any of the afore-mentioned entities.
2.
All documents provided to or received from the U.S.
Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-ceeding, or the licensing of any nuclear powered electric generation plant.
All documents referring or relating to or setting forth neet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S.
Department of Justice or U.S. Nuclear Regulatory Commission.
3.
All documents provided to or received from an attorney for or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting forth~ meetings or conversations with any of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nuclear powered electric generating plant by any electric utility, municipal system, electrical cooperative, or com-bination thereof.
5.
All documents referring or relating to or setting forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
. ~
7.
All documents referring or relating to or setting forth each bulk power supply plan prepared by or for the City of Hearne since January 1, 1973.
8.
All documents referring or relating to or setting forth each in transmission study developed by or for the City of Hearne connection with any of the bulk power supply plans covered in item number 7 above.
9.
All documents referring or relating to or setting forth corre-spondence or contracts between the City of Hearne and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.
10.
All documents referring or relating to or setting forth any correspondence or contracts between the city of Hearne and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or its representatives.
Houston Lighting & Power Company requests that the Keeper of the Records identify the specific reauest or recuests 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 meanina, all or original (or copies where originals are unavailable) and non-identical copies (whether dif ferent from originals by reason of notation made on such copies or otherwise) of all written, recorded or graohic matter, however produced or reproduced, whether or not now in existence', however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar or diary entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
RETURN ON SERVICE Received this subpoena at............................on
...................and on
.................at..........
................... served it on the within names.......
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Total.....................$
Subscribed and sworn to before me, a..................
this......... day of...............,19.....
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY,
)
Docket Nos. 50-498A et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
SUBPOENA TO:
Elton McGinnis Southwest Texas Electric Coop P.O.
Drawer 677 El Dorado, Texas 76936 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R.
S2.720, to appear at the (2500) Bryan Tower, 2001 Bryan Street.In the City of D.al.las.,.
pxas on the 21,st day of. February,1980 at p00A.g.
(and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or objects described in the attached schedule.
Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the
. attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By 19 Douglas G.
Green Attorney for Houston Lighting
& Power Company LOWENSTEIM, NEWMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 862-8400 10 C.F.R.
- 2. 720 (f)
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or ' requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SUBPOENA 1.
All documents which set forth, contain information about, refer or relate to instances of competition in any phase of the electric utility industry involving:
(1) Houston Lighting & Power Company and/or (2) Texas Power and Light Company and/or (3) Texas Electric Service Com-pany and/or (4) Dallas Power and Light Company; or to any communications between Southwest Texas Electric Coop, its~ agents, or employees and any of the aforementioned entities.
2.
All documents provided to or received from the U.S. Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of their consultants or designated witnesses in connection with this pro-ceeding, or the licensing o.f any nuclear powered electric generation plant.
All documents referring or relating to or setting forth meet-ings or conversations with any attorney, consultant, or designated wit-ness for or employee of the U.S. Department of Justice or U.S.
Nuclear Regulatory Commission.
3.
All documents provided to or rec $ived from an attorney for or an employee of:
(1) the Public Utilities Board of the City of Browns-ville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5)
C.
H.
Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Com-pany, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; (7) any other party to this proceeding; (8) any municipality, cooperative, government agency, or entity which operates or proposes to operate electric generation, trans-mission, or distribution facilities in any of the States of Texas, New Mexico, Oklahoma, Arkansas, and Louisiana or in the Republic of Mexico; and (9) any designated witness in this proceeding.
Any documents refer-ring or relating to or setting'forth meetings or conversations with any of the aforementioned entities or individuals.
4.
All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form of participation, in any nuclear powered electric generating plant by any electric utility, municipal system, electrical cooperative, or com-bination thereof.
5.
All documents referring or relating to or setting'forth the desirability, feasibility, benefits or detriments of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.
6.
All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.
. 7.
All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Southwest Texas Electric Coop since January 1, 1973.
8.
All documents referring or relating to or setting forth each transmission study developed by or for the Southwest Texas Electric Coop in connection with any of the bulk power supply plans covered in item number 7 above.
9.
All documents referring or relating to or setting forth correspondence or contracts between Southwest Texas Electric Coop and any electric utility or electric cooperative con-cerning the purchase and/or sale of electric power.
10.
All documents referring or relating to or setting forth any correspondence or contracts between Southwest Texas Electric Coon and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.
Instructions The period of time for which documents are reauested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or its representatives.
Houston Lighting & Power Company requests that the Keeper of the Records identify the specific reauest 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 anu 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 criainals 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, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar or diary entries, maps,
graphs, charts, statistical records, computer data, or papers similar to any of the foregoing, however denomina-ted, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
P-URN ON SERVICE Received this subpoena at............................on
...................and on
.................at..........
................... served it on the within names.......
...................by delivering a copy to h.....and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date..............
19....
By..........................
Service Fees Travel....................$
Services..................$
Total.....................$
Subscribed and sworn to before me, t...................
this......... day of...............,19.....
b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER
)
Docket Nos. 50-498A COMPANY, et al.
)
50-499A
)
(South Texas Project,
)
Units 1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the foregt'ing:
Application for Issuance of Subpoenas and Seven(7) 6ttached Subpoenas all dated February 5, 1980 were served upon the following persons, by hand *, or by deposit in the United States Mail, first class postage prepaid, this 5th day of February, 1980.
C
_A
/
William.T. Franklin
- Marshall E. Miller, Esquire Roy P.
Lessy, Jr., Esquire U.S. Nuclear Regulatory Conmission Frederic D.
Chanania, Esquire Washington, D.C.
20555 Michael B.
Blume, Esquire Ann P.
Hodgdon, Esquire
- Michael L.
Glaser, Esquire U.S. Nuclear Regulatory Commission 1150 17th Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Roff Hardy
- Sheldon J.
Wolfe, Esquire Chairman and Chief Executive U.S. Nuclear Regulatory Commission Officer 4
Fashington, D.C.
20555 Central Power and L.ght Company Post Office Box 2121 Atomic Safety and Licensing Corous Christi, Texas 78403 Aopeal Board Panel U.S.
Nuclear Regulatory Commission G.K.
Spruce, General Manager Washington, D.C.
20555 City Public Service Board Post Office Box 1771
- Chase R.
Stephens, Supervisor (20)
San Antonio, Texas 78203 Docketing and Service Branch U.S. Nuclear Pegulatory Commission Mr. Perry G.
Brittain Washington, D.C.
20555 President Texas Utilities Generating Company Mr. Jerome D.
Saltzman 2001 Bryan Tower Chief, Antitrust and Indemnity Dallas, Texas 75201 Group U.S. Nuclear Regulatory Commission G.W.
Oprea, Jr.
Washington, D.C.
20555 Executive Vice President Houston Lighting & Power comoany J.
Irion Worsham, Esquire p_st vt!!ce Box 1700 Merlyn D.
Sampels, Esquire houston, Texas 77001 Spencer C.
Relyca, Esquire Worsham, Forsyth & Sampels 3.L.
Hancock, Director 2001 Bryan Tower, Suib 2500 City of Austin Electric Utility Dallas, Texas 75201
?ost Office Box 1086 Austin, Texas 78767 Jon C.
Food, Esquire Matthews, Nowlin, "?.cfarlane
~Joseoh Gallo, Esquire
& Barrett Robert H.
Loef?ler, Esquire 1500 Alamo National Building Isham, Lincoln & Beale San Antonio, Texas 78205 1050 17th Street, N.W.,
Suite 701 Charles G.
- Thrash, Jr., Esquire E.W.
Barnett, Esquire Michael I.
Miller, Esquire Theodore F. Weiss, Esquire James A.
Carney, Esquire J.
Gregory Copeland, Esquire Sarah Welling, Esquire Baker & Botts Isham, Lincoln & Beale 3000 One Shell Plaza One First National Plaza Houston, Texas 77002 Suite 4200 R. Gordon Gooch, Esquire Steven R.
Hunsicker, Esquire David M.
Stahl, Esquire Baker & Botts Isham, Lincoln & Beale 1701 Pennsylvania Avenue 1050 17th Street, N.W.
Washington, D.C.
20006 Suite 701 Washington, D.C.
20036 Martha E.
Gibbs, Esquire Isham, Lincoln & Beale One First National Plaza Chicago, Illinois 60603
. Don R.
Butler, Esquire David A.
Dopsovic, Esquire Sneed, Vine, Wilkerson, Selman Frederick H. Parmenter, Esquire Susan B.
Cyphert, Esquire
& Perry Post Office Box 1409 Nancy A.
Luque, Esquire Austin, Texas 78768 Energy Section Antitrust Division U.S.
Department of Justice Mr. William C.
Price P.O. Box 14141 Central Power & Light Company Washington, D.C.
20044 P.O.
Box 2121 Corous Christi, Texas 78403 Morgan Hunter, Esquire Bill D.
St. Clair, Esquire Mr.
G.
Holman King McGinnis, Lockridge & Kilgore West Texas Utilities Company Fifth Floor P.O. Box 841 Texas State bank Building Abilene, Texas 79604 900 Ccngress Avenue Austin, Texas 78701 Jerry L. Harris, Esquire Richard C.
Balough, Esquire W.S.
Robson City of Austin General Manager P.O. Box 1088 South Texas Electric Cooperative, Inc.
Austin, Texas 78767 Route 6, Building 102 Victoria Regional Airport Joseph B.
- Knotts, Jr.,
Esquire Victoria, Texas 77901 Nicholas S. Peyriold s, Esquire Debevoise & Liberman Robert C. McDiarmid, Esquire 1200 17th Street, N.W.
Robert A. Jablon, Esquire Washington, D.C.
20036 Marc R.
Poirier, Esquire Spiegel & McDiarmid Don H. Davidson 2600 Virginia Avenue, N.W.
City Manager Washington, D.C.
20037 City of Austin P.O. Box 1088 Kevin B.
Pratt Austin, Texas 78767 Texas Attorney General's Office P.O.
Box 12548 Jay Galt, Esquire Austin, Texas 78711 Looney, Nichols, Johnson & Hays 219 Couch Drive William H. Durchette, Esquire Oklahoma City, Oklahoma 73102 Frederick H. Ritts, Esquire Law Offices of Northcutt Ely Knoland J.
Plucknett Watergate 600 Building Executive Director Washington, D.C.
20036 Committee on Power for the South-west, Inc.
Tom W.
Gregg, Esquire 5541 East Skelly Drive P.O. Box Drawer 1032 Tulsa, Oklahoma 74135 San Angelo, Texus 76902 John W.
Davidson, Escuire Leland F. Leatherman, Esquire Sawtell, Goode, Davidson & Tioili McMath, Leatherman & Woods, P.A.
1100 San Antonio Savinsg Building 711 West Third Street San Antonio, Texas 78205 Little Rock, Arkansas 72201 Douglas P.
John, Esquire Paul W.
Eaton, Jr., Esquire Akin, Gump, Hauer & Feld Hinkle, Cox, Eaton, Coffield & Hensley 1333 New Hamnshire Avenue, N.W.
600 Henkle Building Suite 400 P.O.
Box 10 Washington, D.C.
20036 Roswell, New Mexico 88201
Robert M.
Rader, Esquire Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 W.N. Woolsey, Esquire Kleberg, Dyer, Redford & Weil 1030 Petroleum Tower Corpus Christ, Texas 78474 Donald M.
Clements, Esquire Gulf States Utilities Company P.O. Box 2951 Beaumont, Texas 77704 Dick Terrell Brown, Esquire 800 Milam Building San Antonio, Texas 78205 C.
Dennis Ahearn, Esquire Debevoise & Liberman 1200 Seventeenth Street, N.W.
Washington, D.C.
20036