ML19312D700
| ML19312D700 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 03/14/1980 |
| From: | Lazo R Atomic Safety and Licensing Board Panel |
| To: | Stagg G AFFILIATION NOT ASSIGNED, STAGG SYSTEMS, INC. |
| References | |
| NUDOCS 8003250208 | |
| Download: ML19312D700 (4) | |
Text
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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HOUSTON LIGHTING & POWER COMPANY
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NRC Docket Nos. 50-498A PUBLIC SERVICE BOARD OF SAN ANTONIO
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50-499A CITY OF AUSTIN
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CENTRAL POWER AND LIGHT COMPANY
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(South Texas Project, Unit Nos.
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1 and 2)
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TEXAS UTILITIES GENERATING
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NRC Docket Nos. 50-445A COMPANY, et al.
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50-446A (Comanche NaTSteam Electric
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Station, Units 1 and 2)
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SUBPOENA TO:
Glenn W. Stagg Stagg Systems Inc.
261 Madison Avenue New York, N. Y.
10016 YOU ARE HEREBY COMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. 5 2.720, to appear at the U. S. Department of Justice offices, 26 Federal Plaza (Room 3630), New York, New York 10007 on the 31st day of March,1980 at 9:00...m. (and thereafter from day to day, if necessary) and then again on May 1,1980 (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) er 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 of documents.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD
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By he Tik. fw R& CLs DSI-0 P v
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SCHEDULE TO SUBPCENA 1
All documents referring or relating to or setting forth the desirability, feasibility (engineering, economic or otherwise), benefits or detriments of interconnecting the electric systems or electric utilities in the Texas Interconnected Systems and/or the Electric Reliability Council of Texas and (1) any other electric systems engaged in interstate comerce, (2) the South West Power Pool, and/or (3) the Western Systems Coordinating
- Council, 2
All documents referring or relating to or setting forth any adverse effects or positive effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council with (1) any other electric utility engaged in interstate commerce, (2) the South West Power Pool, and/or (3) the Western Systems Coordinating Council.
3 All documents provided to or received from D. E. Simons, of the Houston Lighting & Power Company.
4.
All documents provided to or received from Kermit Williams, of the Houston Lighting & Power Company.
5.
All documents provided to or received from John Meyer, of the Houston Lighting & Power Company.
6.
All documents provided to or received from R. McCuistion, of the Houston Lighting & Power Company.
7.
All documents provided to or received from any other employee of or consul-tant to the Houston Lighting & Power Company.
8 All-other documents provided to or received from anyone which were re-ferred to or consulted during the preparation, and publication of any studies done by Stagg Systems, Inc. or Glenn W. Staff for Houston Lighting
& Power Company which relate to the subject matter of interconnections or the lack of interconnections between electric utilities in the Texas Interconnected Systems and the Electric Reliability Council of Texas and any other electric utilities involved in interstate comerce.
9.
All documents which may or will be relied upon or which are related to any actual or perspective testimony by Glenn W. Stagg before the (1) Securities and Exchange Comission, (2) the Federal Energy Regulatory Comission (3) the Nuclear Regulatory Comission as relates to any electric utilities in the Electric Reliability Council of Texas, the South West Power Pool, or any adjacent area.
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DEFINITIONS 1.
" Document" means, without limiting the generality of its meaning, all 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, telegramss 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, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
CLAIM OF PRIVILEGE If any document is withheld under claim of privilege, furnish a list which identifies each document for which privilege is claimed and which includes the following information for each such document: date, subject matter, sender, recipient, persons to whom copies were furnished together with their job titles, the basis on which privilege is claimed, and the paragraph of this subpoena to which such documents responds.
INSTRUCTIONS It is requested that the documents submitted be grouped according to the individual paragraph of the subpoena section to which they are responsive and, within each such group, the documents should be arranged, as much as possible, in chronological order.
In order to facilitate the handling of the documents which will be received it would be appreciated if each of the documents would be numbered consecutively.
It is suggested that in numbering the documents each page be numbered, except in those instances where the documents are bound together, when numbering only the first page is appropriate. This procedure, if followed, will preserve the identity of all the documents coming from the company, and also insure the accurate and expeditious return of these documents to the company.
j In lieu of producing these documents at a deposition, the Department of Justice and the NRC Staff are willing to discuss other arrangements for production of documents prior to the deposition which may be agreeable to counsel.
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The time period covered by this subpoena is 1973 to the present.
Should any questions arise concerning this subpoena, please contact Susan B. Cyphert (202-724-6472 or 724-6361) or Fredric D. Chanania (301-492-8665) at the following addresses:
Susan B. Cyphert Fredric D. Chanania Department of Justice U. S. Nuclear Regulatory Comission, OELD P. O. Box 14141 Washington, D. C.
20555 Washington, D. C.
20044 i
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