ML19296D268
| ML19296D268 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 02/13/1980 |
| From: | Green D HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| NUDOCS 8003030137 | |
| Download: ML19296D268 (27) | |
Text
s' g.
f,C N$\\
[ A '#hh O
' g.
77)
UNITED STATES OF AMERICA si
'/
'g y
(/
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD T
% -j y In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY
) Dockat 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 FOR ISSUANCE OF SUBPOENAS Houston Lighting & Power Company, pursuant to 10 C.F.R.
SS2.740 and 2.741, applies for the issuance of the attached Subpoenas, which call for a deposition requiring 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)
John W.
Turk, Jr.,
Southwestern Electric Power Company (2)
Martin E.
Fate, Public Service Company of Oklahoma 8003080
3 (3)
Durwood Chalker, Central Power & Light Company Respectfully submitted, o
I,.)-1%
EL>n NouhlasG.
Green Attorney for Houston Lighting &
Power Company OF COUNSEL:
BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 Lowenstein, Newman, Reis Axelrad & Toll 1025 Connecticut Avenue, N.W.
Washington, D. C.
20036 Dated:
February 13, 1980
'n 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:
Durwood Chalker Central Power & Light Company P.O.
Box 2121 Corpus Christi, Texas 78403 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)
B,ry,an, Tower,,,2,00A Eryan Et in the City of
- paJlps, f*.as on the 25,th. day o f.. F,eb,ru,ary,, 1,9 8,0,
at 9y30 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, 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 stapoena is directed, and on notice to the par.ty at whose instance the subpoena was issued, the presiriing 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 SU3PCEMA refer forth, contain information about, All documents which set l
t ic or relate to instances of competition in any phase of the e ec rHouston Lightin 1.
(1)
Texas Electric Service Ccm-utility industry involving:
(3)
Texas Power and Light Ccapany and/orDallas Power and Light Company; (2) nd between Central Power and Light Company, its agents, or employees a pany and/or (4) any of the aforementioned entities.
All dccuments provided to or received from the U.S. Depart-
' on or any of ment of Justice or the U.S. Nuclear Regularory Commisrn. Ocnnec: _en with this p 2.
their consultants or designated witnesse-ation ceeding, or the licensing of any nuclea e powered electric gener h meet-All documents referring or relaC.ng to or setting fortor designated wit-ings or conversations with any attorney, consultant, plant.
U.S. Nuclear ness for or employee of the U.S. Department of Justice or Regulatory Commission.
All documents provided to or received from an attorney the Public Utilities Board of the 3.
(1)
Inc.;
Tex-La Electric Cooperative, for or an employee of:
(2)
(4) Tex-La of Texas, City of Brownsville, Texas;the Committee on Power for the Southwest; Central (6)
(3)
C. H. Guernsey Corporation; ih t limitation Corporation and/or any of its subsidiaries including w (5)
Inc.;
(7 )
and Southwestern Electric Pouer Company;any municipality, cooperative, gove proceeding; (8) i eration, trans-entity which operates or proposes to operate eleccr c gen f Texas, New mission, or distribution facilities in any of the States oand Louisiana or in the Any documents re fer-Mexico, Oklahoma, Arkansas, any designated witness in this proceeding.
i h any ring or relating to or setting forth'meetin,gs or conversations w t and (9) of the aforementioned entities or individdals'.
l All documents referring or relating to or cetting forth eva ua-ther form tions as to the benefits or detriments of ownership, or any oin any 4.
i ccm-any electric utility, municipal system, electrical cooperat ve, or of participation, bination thereof.
All documents referring or relating to or setting fort the S.
i electric systems in the Texas Interconnected Systems and the Electr c desirability, Reliability Council of Texas and (1)
(2) Western Systems Cocrdinating Council.
setting forth any All documents referring or relating to or lack of interconnec tions 6.
adverse effects resulting from the presentInterconnected Svstems and/or the Ele (2) the We sterr between the Texas the Southwest Power Pcol and/or Council of Texas with (1)
S73 tens Cecrdinating Council.
2-
~
All documents referring or relating to or setting forth each Central Power & Light bulk pcwer supply plan prepared by or fer the 7.
Company since January 1, 1973.
All documents referring or relating to or setting forth each
& Light transmission study developed by or for the Central Power 8.
d Company in connection with any of the bulk power supply plans covere in item number 7 above.
All documents referring or relating to or setting forth corre-and any electric utility or electric cooperative concern ngsp 9.
i ths pur-chase and/or sale of electric power.
All documents referring er relating to or setting forth any correspcadence or contracts between the Central Power & Light Company 10.
and any electric utility or electric cooperative concerning rating of the uurchase and/or sale of fuel to be used for the gene electric power.
f All of your personal files, whether maintained outside o,
or in the course of your duties with Central Power & Light Company 11.
or West Texas Utilities Company, which contain information about, refer, or relate to any subject covered in items 1-10 above.
'i' l 9
e
Instructions The period of ttne for which documents are requested in-cludes the entire period from January 1, 197n te the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.
Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive.
Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsivle to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, minutes of directors' cr committee meetings, memoranda, inter-office communications, s udies, analyses, notes, books, records, reports, sunmaries and results of investigations and tests, reviews, contracts, agreements,
a pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, hewever denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
1 RETURN ON SERVICE on Received this subpcena at
............... and on................ at...............
served it on the within named........
..................... by delivering a copy to h....
and tendering to h.... the fee for one day's attendance and the mileage allowed by law.
Dated............
19....
By...........................
Service Fees Travel
..................S Services.................S Total....................$
Subscribed and sworn to before me, a...................
19....
this..... day of
e-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC S AFETY 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:
John W. Turk, Jr.
Southwestern Electric Power Company P.O. Box 1106 Shreveport, Louisiana 71154 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act oggg9h4, as amended, and 10 C.F.R. 52.720, to appear at the 0
Bryan Tower 2001 Brya.n.St..
in the City of
.Da.ll.as.
epas on the. 2,6 t,h day o f. F,eb,ru,ary,,1,9 8,0,
at 9:30 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 Conpany 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 or requires evidence not relevant to any ma'tter in issue, or (2) condition denial of the motion on just and reasonable terms.
SCHEDULE TO SU3PCE:!A refer forth, contain information about, 1.
All documents which set or relate to instances of competition in any phase of the electric (1) Houston Lighting & Power Co pany and/or utility industry involving:Company and/or (3) Texas Electric Service Ccm-Callas Power and Light Company; or to any communications (2) Texas Power and Light between Southwestern Electric Power Company, its agents, or employees pany and/or (4) and any of the aforementioned entities.
All dccuments provided to or received from the U.S. Depart-f ment of Justice or the U.S. Nuclear Regulatory Commission or any o 2.
i h this pro-their consultants or designated witnesses in connection w t i
ceeding, or the licensing of any nuclear powered electric gene ings or conversations with any attorney, consultant,of Justice or U.S. Nuclear plant.
ness for or employee.of the U.S. Department Regulatory Commission.
All documents provided to or received from an attorney the Public Utilities Board of the 3.
for or an employee of:
(1)
Inc.;
Tex-La Electric Cooperative, (2)
City of Brownsville, Texas;the Committee on Power for the Southwest; Central an (4) Tex-La of Texas, (3)
C. H. Guernsey Corporation; (6) limitation Corporation and/or any of its subsidiaries including witho Inc.; (5) d (7) any other party to this Public Service Company of Oklahoma:
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, Newand Any documents refer-Mexico, Oklahcra," Arkansas, any designated witness in this proceeding.
ring or relating to or setting forth meetings or conversations with any and (9)
~
of the aforementioned entities or individuilsr, All dccuments referring or relating to or setting forth evalua-form tions as to the benefits or detriments of ownership, or any othe 4.
ag.y electric utility, municipal system, electrical cooperative, or ccm-of participation, bination thereof.
All documents referring or relating to or setting forth the the feasibility, benefits or detriments of interconnectine 5.
electric systems in the Texas Interconnected Systems and the Elect:icPower Pool, a ce sirability,
Reliability Council of Texas and (1) the Southwest (2) Western Systems Coordinating Council.
All documents referring or relating to or setting forth any 6.
lack of interconnections adverse effects resulting from the present h
Electric Reliability Ccunc?n the Tenas In:erconnected Systems and/or t ethe Southwest Power P "Ot"0 1
- 'eMas wita (1)
~~ c:
SYstens Cccrdinatin: Council.
4
. All documents referring or relating to or settin'g forth each Southwestern Electric 7.
bulk power supply plan prepared by or for the Power Company since January 1, 1973.
All dccuments referring or relating to or setting forth each Southwestern Electric Power 8.
transmission study developed by or for the Company in connection with any of the bulk power supply plans covered in item number 7 above.
All documents referring or relating to or setting forth corre-and any electric utility or electric cooperative concerning th 9.
chase and/or sale of electric power.
All documents referring or relating to or setting forth any correspcadence or contracts between the Southwestern Electric Power 10.
Company and any electric utility or electric cooperative concerning f
the ourchase and/or sale of fuel to be used for the generating o electric power.
All of your personal files, whether maintained outside of, or in the course of your duties with Southwestern Electric Power 11.
refer, or relate to any Company, which contain information about, subject covered in items 1-10 above.
i s
Instructions The period of time for which documents are requested 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 Texas Utilities Generating company or their representatives.
Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive.
Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsivle to this Subpoena, which are found together in the Keeper of the Records' files.
If you claim that any docu=ent requested hereunder is privileged, with respect to each such document, please provide the folicwing:
(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other descriptien necessary to enable the custodian to locate the particular docu=ent; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.
" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, minutes of directors' or co=mittee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, sc=naries and results of investigations and tests, reviews, contracts, agreements,
e s
pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
O e
O
RETURN ON SERVICE
............ on Received this subpcena at and on................ at served it on the within named........
..................... by delivering a copy to h.... and tendering to h....
the fee for one day's attendance and the mileage allowed by law.
Dated............
19....
By...........................
Service Fees Travel Services.................$
Total....................$
Subscribed and sworn to before me, a...................
this..... day of..................,
19....
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:
Martin E. Fate Public Service Company of Oklahoma P.O. Box 201 Tulsa, Oklahoma 74101 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act 52.720, to appear at the of 1954,) as amended, and 10 C.F.R.
(2500
,Brya,n,To,we,r,, 2,0 0,1,Bry a,n,S t,.
in the City of'.
.Da,1(a s,
.T e,x a,s.
on the 27,th. day of. F,pb,rg,ary, L9 8,0,
at 9:30,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, NEWMAN, REIS, AXELRAD & TOLL 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 862-8400 10 C.F.R.
- 2. 7 20 (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 SU3?OEMA forth, contain information about, refer All documents which set or relate to instances cf cc= petition in any phase of the electricPower Coppany and/or 1.
utility industry involving:
(1) Mcuston Lighting &
(3) Texas Electric, Service Ccm-Texas Power and Light Company and/orDallas Power and Light Company; or to (2) pany and/or (4) between Public Service Company of Oklahoma, its agents, or employees and any of the aforementioned entities.
All dccuments provided to or received frc= the U.S. Depart-ment of Justice or the U.S. Nuclear Regulatory Commission or any of 2.
his pro-their censultants or designated witnesses in connection with t ceeding, or the licensing of any nuclear powered electric gen plant.
ings or conversations with any attorney, consultant, ness for or employee.cf the U.S. Department of Justice or U.S. Nuclear Regulatory Commission.
All documents provided to or received from an attorney the Fublic Utilities Board of the 3.
for or an employee of:
(1)
(2) Tex-La Electric Cooperative, Inc.;
City of Brownsville, Texas; (4) Tex-La of Texas, the Committee on Power for the Southwest; Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest (3)
Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, and (7) any other party to this Southwestern Electric' Power Company; proceeding; (B) any municipality, ccoperative, government agency, or entity which operates or proposes to operate electric generation,. trens-mirsion, or distribution facilities in any of the States of Texas, Newand L Mexico, Oklahcma, Arkansas, Any documents ref er-any designated witness in this prececding.
~
ring or relating to or setting forth meetings or conversations with an?
and (9) of the aforementioned entities or individu61s7, All documents referring or relating to or setting forth evalua-tions as to the benefits or detriments of ownership, or any other form 4.
in any nuclear powered electric generating plant by of participation, any electric utility, municipal system, electrical cooperative, or ccm-bination thereof.
All documents referring or relating to or setting forth the the feasibility, benefits or detriments of intercennectine 5.
electric systems in the Texas Interconnected Systems and the Electric desirability, Reliability Council of Texas and (1) the Southwest Power Pool, and/cr (2) Western Systems Cecrdinating Council.
All documents referring or relating to or setting forth any 6.
lack of interconnections adverso ef fects resulting frcm the present
[IU 77 th.e Texas Inrerconnected Systems and/or the Electric Rel
. Texas with (1) the Southwest Power Pccl and/or (2) the Western e,. : c - 0 :
"; o ens Cccrdinating Ccuncil.
. ~
All documents referring or relating to or setting forth each bulk power supply plan prepared by or for the Public Service Company 7.
of Oklahoma since January 1, 1973.
All documents referring or relating to or setting forth each transmission study developed by or for the Public Service Company of 8.
Oklahoma in connection with any of the bulk power supply plans covered in item number 7 above.
All docunents referring or relating to or setting forth corre-Public Service Company of Oklahoma 9.
spondence or centracts between the and any electric utility or electric cooperative concerning the pur-chase and/or sale of electric power.
All documents referring or relating to or setting forth any 10.
correspondence or contracts between the Public Service Company of Oklahoma and any electric utility or electric cooperative conerning the ourchase and/or sale of fuel to be used for the generating of electric power.
All of your personal files, whether maintained outside of, or in the course of your duties with Public Service Company of 11.
refer, or relate to any Oklahoma, which contain information about, subject covered in items 1-10 above.
J
e Instructions The period of time for which documents are requested 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 Texas Utilities Generating Company or their representatives.
Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive.
Where possible, the Keeper of the Recorde is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsivle 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 ccnfidential nature of any such document.
" Documents" means, without liniting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, minutes of directors' cr co=nittee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements,
a pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, ccmputer data or papers similar to any of the foregoing, however dencminated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
O
RETURN ON SERVICE
............ on Received this subpoena at and on................ at served it on the within named........
..................... by delivering a copy to h....
and tendering to h....
the fee for one day's attendance and the mileage allowed by law.
Dated............
19....
By...........................
Service Fees Travel Services.................$
Total....................$
Subscribed and sworn to before me, a...................
this..... day of..................,
19....
a 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 COMPANY
)
Docket Nos. 50-445A et al.
)
50-446A
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
~
CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the foregoing:
APPLICATION FOR ISSUANCE OF SUBPOENAS to John W. Ti-k, Jr., Southwestern Electric Power Company, Martin Fate, Public Service Company of Oklahoma and Durwood Chalker, E.
Central Power & Light Company were served upon the following persons,.
by hand *, or by deposit in the United States Mail, first class postage prepaid, this 13th day of February, 1980.
i n-tun j
- Marshall E.
Miller, Esquire Roy P.
Lessy, Jr., Esquire U.S. Nuclear Regulatory Commission 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 Washington, D.C.
20555 Central Power and Light Company Post Office Box 2121 Atomic Safety and Licensing Corpus Christi, Texas 78403 Aupeal Board Panel U.S. Nuclear Regulatory Commission G.K.
Spruce..aneral 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 Regulatory 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 Grouc N' clear Regulatory Commission G.W.
Oprea, Jr.
U.S.
u Washington, D.C.
20555 Executive Vice President Houston Lighting & Power Comoany J. Irion Worsham, Esquire post Office Box 1700 Me rly n D. Sampels, Esquire Houston, Texas 77001 Spencer C.
Relyea, Esquire Worsham, Forsyth & Sampels R.L.
Hancock, Director 2001 Bryan Tower, Suite 2500 City of Austin Electric Utility Dallas, Texas 75201 Post Office Box 1086 Austin, Texas 78767 Jon C. Wood, Esquire Matthews, Nowlin, Macfarlane Joseoh Gallo, Esquire
& Barrett Robert H.
Loeffler, Esquire 1500 Alamo National Building Isham,' Lincoln & Beale San Antonio, Texas 78205 1050 17th' Street, N.W.,
Suite 701 Washington, D.C.
20036 Charles G.
Thrash, Jr., Esquire E.W.
Earnett, 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 Chicago, Illinois 60603 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
& Perry Susan B.
Cyphert, Esquire 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 Corpus 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 Congress 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.
Peynolds, Esquire Debevoise & Liberman Robert C. McDiarmid, Esquire 1200 17th Street, N.M.
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,.-Burchette, 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, Texas 76902 John W.
Davidson, Escuire Leland F. Leatherman, Esquire Sawtell, Goode, Davidson & Tioili McMath, Leatherman & Woods, P.A.
1100 San Antonio Savings Building 711 West Third Street San Antonio, Texas 78205 Little Rock, Arkansas 72201 Douglas F.
John, Esquire Paul W. Eaton, Jr., Esquire Akin, Gump, Hauer & Feld Hinkle, Cox, Eaton, Coffield & Hensley 1333 New Hampshire 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.
Dent 2s Ahearn, Esquire Debevoise & Liberman 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 1
+e$