ML19317E539
| ML19317E539 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, McGuire  |
| Issue date: | 04/12/1973 |
| From: | Ragong S VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| Shared Package | |
| ML19317E536 | List: |
| References | |
| NUDOCS 7912180764 | |
| Download: ML19317E539 (2) | |
Text
'
' O, UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of
)
AEC Docket Nos. 50-269A
)
50-270A DUKE POWER COMPANY
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50-287A
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50-369A (Oconee Units 1, 2, and 3;
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50-370A McGuire Units 1 and 2)
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Affidavit of Stanley Ragone of Virginia Electric and Power Company in Response to Order of March 22, 1973 and in Support of a Motion to Quash or to Limit the Subpoena of November 20, 1972 STANLEY RAGONE, being first duly sworn, deposes and says:
I am Senior Vice President of Virginia Electric and Power Company, which was served with a subpoena duces tecum dated November 20, 1972 by the Department of Justice.
I am generally familiar with the contents of the subpoena and have participated in discussions concerning an appropriate response thereto.
The subpoena defines 'oroad subj ect matter categories of documents.
An adequate search for all relevant documents 7913180[df
~
2.
will require a review of many different files located at different places.
Individual files as well as company files will have to be reviewed.
The breadth of the specifications will make the search extremely burdensome.
In addition, the subpoena calls for all documents in the defined categories since January 1, 1940.
Files containing any such documents are located in a vault apart from company offices and would require very substantial time and effort to survey thoroughly.
Those persons who might have been familiar with files containing documents of ten, twenty or thirty years of age are now for the most part deceased, retired or transferred to other locations, and would not be available for assistance in the search.
In short, the review of all files necessary to comply with this subpoena will take many man-hours by personnel un-familiar with the matter and will be an extremely difficult task.
[
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_ = -M W
Stanley Rag W C./
Senior Vice President Virginia Electric and Power Company Richmond, Virginia Subscribed and sworn to before me on this the
/A
- day of Sp d 1973.
CLk'ar-416.t -
u No$ary Publi'c My commission expires: @u~~h /o2
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