ML19351D589
| ML19351D589 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 10/07/1980 |
| From: | Green D HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| ISSUANCES-A, NUDOCS 8010140004 | |
| Download: ML19351D589 (27) | |
Text
0-e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter'of
)
HOUSTON LIGHTING & POWER
)
COMPANY, et al.
(South
)
Docket Nos. 50-498A Texas Project, Units 1
)
50-499A and 2)
)
)
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
(Comanche
)
Docket Nos. 50-445A Peak Steam Electric Station,
)
50-446A Units 1 and 2)
)
7 /).,.,-
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( Lv - t RESPONSE OF HOUSTON LIGHTING AND POWER COMPANY TO MOTIONS OF THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE FOR DISAPPROVAL OF NEGOTIATED LICENSE CONDITIONS AND FOR DELAY IN COMING FORWARD WITH EVIDENCE AND BRIEFS At the prehearir.g c ence on Septamber 15, 1980, this Board invited those parte.cs which had nc $ settled their anti ~
trust contentions to comment on the license conditions negotiated by Applicants, the NRC Staff, the Department of Justice, and others.
On September 25, 1980 the Public Utilities Board of the City of Brownsville, Texas (PUB) filed a document styled as a motion for rejection of the settlement, containing a melange of accusations, and concluding with the suggestion that PUB has a right to have the governmental parties which have settled put on a case for it.
Absent in PUB's pleading was any reference to the evidentiary or legal basis for PUB's antitrust claims or any identification of the relief sought by PUB or the alleged basis therefor.
Under the procedural schedule long in effect pursuant to orders of this Board anr', explicitly reaffirmed at the September 15 8 010140 oog
O o conference (Tr. 1023 ) (remarks of Mr. Glaser) PUB is obligated to come forward with its Trial Brief and the evidentiary basis of its claims, on October 8, 1980.
However, in a second motion dated October 3, 1980 (but not received until mid-day October 6),
at the eleventh hour, PUB now asks to be relieved of that obligation.
Houston Lighting & Power Company (Houston) opposes both 1/
of PUB's motions.-
If any progress is to be made towards the expeditious resolution of this matter, PUB simply must l
meet its litigant's obligation' to put its ccrds on the table.
I.
We turn first to PUB's self-styled motion for rejection of the settlement.
That motion relies r.:telusively on " comments" of counsel, virtually none of which are consistent with the facts or the law in this case.
All of these " comments," stripped of their rhetoric, embody the same proposition:
the settlement does not accord with i
PUB's view of the merits therefore it is wrong.
PUB evidently contends it can demonstrate a situation inconsistent with the antitrust laws beyond what any other complainant has perceived, and can demonstrate an entitlement to relief that goes beyond the settlement conditions.
Houston regards such a contention as palpably without merit, factually and legally.
1/
Because the two PUB motions are interrelated, and because both seek to impose roadblocks to the settlement of this case, we deal with them together in this pleading.
. l For all its verbiage, PUB's commentary never identifies I
the situation inconsistent with'the antitrust laws or suggests s
l appropriate remedial conditions.
This, however, is the key to 4
any relief to which PUB can claim an entitlement.
Exchange of 4
unsubstantiated argument will not advance the resolution of l
this question.
It can be resolved only by putting PUB to its 1
proof.
What relief is sought and what are the evidentiary and legal bases therefor?
These are questions PUB completely avoids in its motion.
Yet until they are answered, meaningful progress towards further resolution of this case will not be l
possible.
l J
i II.
1;-
The filing of Trial Briefs, exhibits, and witness summaries, i
and the institution of the stipulation process, as envisioned in the Board's prior procedural Orders, is precisely what the I
next step here must be if progress is to ensue.
PUB's last second motion to halt this step is an unwarranted attempt to block forward movement toward a resolution on the merits.
1 PUB served its motion only three days prior to its filing deadline, yet PUB has known of its obligations for months.
The Board on July 17, 1980 (well' after the D.C.
interconnection plan had been promulgated), established a September 12, 1980 date for the filing of Trial Briefs and related materials;.this deadline was extended by Order dated September 8, to the current October 8 date.
PUB, unless it has flouted these Orders, has l
its Trial Brief in hand and is prepared to try its case.
)
i
. The primary argument for delay advanced in PUB's motion is that it believes a prehearing conference would help clarify certain aspects of the settlement and various procedural matters.
This is no reason to refuse to go forward.
It is plain that any further progress in this case is dependent on PUB, the only party whien indicates it wishes to go to trial, coming forward and presenting the evidence, the testimony, exhibits and claims for relief which it intends to try.
Decisions as to the procedures for the case would be facilitated immeasurably by PUB's compliance and its filing.
Upon the filing of PUB's Brief, the Board may well determine that the matters asserted by PUB can be readily disposed of through summary disposition.
If a hearing is required, the Board cannot determine the l
length and the scope of such hearing until it is apprised i
of what PUB purports to demonstrate, both with respect to l
liability and relief.
It simply is time for PUB to come forward with more than rhetoric.
I III..
i That PUB is loathe to come forward with its alleged case I
against Houston is understandable.
Located at the southernmost tip of Texas, some 350 miles from Houston's service area (a distance comparable to the distance between Washington and l
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. Hartford), PUB has never had its operations adversely affected in any way by Houston, much less has PUB been in any competitive relationship with Houston.
Even beneath the rhetoric of PUB's motion to disapprove the settlement it is apparent that PUB's real complaint here is that it has been unable to prevail upon Central Power & Light Company, its wholesale power supplier, to extend to PUB the kinds of power supply arrangements PUB would prefer.
PUB's own testimony makes it clear that PUB has never identified any interstate power it has been denied, has never determined whetl.er interstat'e interconnections would be more or 1/
less economical to it,-
and simply has no credible case whatever 2/
regarding interstate interconnections. -
1/
Deposition of Larry Gawlik, PUB's current Chief Engineer
~
at 203-04; deposition of Ruben Edelstein, Mayor of Browns-ville and ex officio member of PUB at 138-39; deposition of Robert Roundtree, General Manager of PUB at 166-67.
Mr. Israel Lizka, Chairman of the PUB from 1974-78, a time period encompassing most of the events which have been the subject of discovery in this lawsuit, testified that at the end of his tenure on the PUB he did not know whether TIS was an interstate or intrastate system and it did not make any difference to PUB one way or the other.
Deposition at 163.
Copies of the pages cited above are annexed hereto.
_2/
For example counsel for PUB this year advised the Board:
MR. POIRIER:
...Brownsville is not focused on the intrastate-interstate issue in this case.
We are relying on the government to do a thorough job and we hope the Board will take into consideration the opinions of their attorneys...
(Tr. 596-97).
I This perhaps helps explain why PUB desires to have the Staff and the Department put on its case for it.
PUB clearly has no case of its own.
But PUB is presumably the proponent of relief here beyond what th government has sought and as such has the burden of going forward like any other litigant and i
1/
has no right to proceed at the public's expense.~
Under PUB's argument moreover, settlement with the governmental parties l
w would be impossible, hardly a rational or desirable result.
While claiming to be amenable to expeditious resolution i
of this matter, PUB recently has repeatedly refused to provide answers to Interrogatories never completed and due long ago, has refused to engage in a process of stipulations with counsel for Houston and has refused to agree upon dates to effect deposi-tions ordered by the Board months ago, terming such wrap-up discovery " premature."
Exhs. B-D. ~2/
1/
PUB appears to argue that because it is smaller than some of the parties to this case it should be accorded special treat-ment at the trial.
PUB garnered over $20 million in revenue in the past year; it has hired two law firms in this pro-ceeding, with four of these lawyers signing its motion attack-ing the settlement; and has followed a policy of intervening in regulatory proceedings where its interests are at stake.
Roundtree Deposition at 13.
It simply cannot in good faith be heard to say the relatively brief time necessary to try whatever its claims may be here is debilitating.
2/
Houston intends to file a related motion to compel shortly.
. i Houston strongly urges the Board to deny PUB's motions and to order PUB to comply with the procedural schedule.
This is the only course likely to facilitate expeditious resolution of this case.
PUB has no desire or incentive to do so here.
Rather, it is plain that PUB seeks to delay the progress of this proceeding, in order to obtain targain-ing leverage which may enable it to extract from Applicants economic concessions wholly unrelated to any antitrust injury and to which PUB is not lawfully entitled.
PUB's motions should be denied.
Respectfully submitted,
,s
/
Dougf'as~G!Grben M/
Attorney for Houston Lighting
& Power Company 1
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:
October 7, l's 8 0
4 4
0
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J EXHIBIT A i
4 i
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GAWLIK 203 1
you, are you talking about the benefits versus 2
the detriments of making that interconnection?
3 MR. FLYNN:
I am talking about l
4 anything which he might testiTy to with regard I
5 to the entity.
6 A I would suspect,I Russ, that anything that would 1
g 7
affect Brownsville to any degree, either econo-f 8
mically -- that if I was called to testify I 9
would be a likely candidate to testify in that I
10 particular area.
11 MR. JOHNSON: Let me see if I can 12 clarify it.
13 Mr. Gawlik is not familiar with 14 any studies, as I understand it, that have been 15 done to the relative benefits of connecting 16 interstate versus intrastate operations.
If 17 that is what you're.getting at.
l l
18 Q Is that correct?
~
19 A well, I have a copy of them, I haven't read them.
20 Gene Simmons gave me a copy of 21 the study that Houston Lighting and Power had 22 done by somebody, some P.H.D.,
somebody that g
23 says one thing, and I have a copy of another n_
24 study that the Department of Energy or somebody 25 sent me that says something else.
But, I haven't u
GAWLIK 204 1
delved into any of those studies to know the l-2 fa: tors upon which they were based, or any of 3
those -- any of the particular parameters upon 4
which the conclusions were reached.
5 Q
So, sime you have come here, since you have come l
6 to Brownsville,lis it fair to say that the 7
interconnection issue has been one that you have 8
not done much reading about or focused on in your 9
system planning for PUB?
10 A
I would say that at this point in time that 11 would be an accurate statement.
I have more t
12 concentrated on the direct economic benefits 13 to Brownsville in working with its immediate 14 neighbor, and with the TIS memb rs, more than 15 I have concentrated on worrying about other 16 entities that are involved in these other 17 proceedings that you are making reference to.
I 18 0
Okay.
Thank you.
19 A
However, in that regard, you know, once somebody 20 shows me that is a more economic way to do it, 21 I am ready to take that one on.
22 MR. GREEN:
We are to, but nobody 23 has been able to do that.
I 24 MR. JOHNSON:
I don't anticipate 25 that he is going to be asked to testify as to e
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!O P Of h bjb EDELSTEIN i LUbu ou ~
l Union Carbide plant arose in early 1976, did the 2
Public Utilities Board through fi r. Lizka take the l'
3 position that it was the only entity that was 4
allowed to serve in the Brownsvillo Navigation 5
District by virtue of its franchise?
l G
A.
Yes, I think so.
7 Q.
Okay.
E 8
A.
Well, not only that, but the Public 9
Utilities took the position that this was an area 10 certified by the Public Utilities Commission and 11 that we had exclusive rights to serve in the area 12 that was assigned to us.
13 Q.
But there was no Public Utilities 14 Connission in the spring of 1976, was there?
15 A.
Yes, we had the area certified prior to 16 that time.
17 Q.
Okay.
Did you have the city attorney i
18 write a letter to anyone with respect to service 19 within the Drownsville Navigation District and 20 the right to serve?
=
21 A.
I don't remember.
l 22 Q.
While you were either chairman of the I
23 Board or mayor, did the Public Utilities Board 24 over consider an interstate interconnection, an 25 interconnection with a utility operating outside i
- 3. n gg. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _3 9 c
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EDELSTEIN I
1 the State of Texas?
.f 2
A.
No, not that I can reco11cet.
l I
3 Q.
Did the Public Utilities Board while you m
4 were mayor desire such an interconnection for j
J l
5 Central Power & Light Company?
^
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G A.
I don't think we were ever asked.
7 Q.
Are you awaro that Central Power & Light B
Company operated in interstate conmerce during a 9
portion of 1976 and 19777 10 A.
It was just hearsay as far as I an
-8 11 concerned.
I was told thgt they were f
I 12 interconnected with one of their associate 13 companies in Oklahoma, I believe it was, or 14 Oklahona or New Mexico, I don't know, but one of 15 the conpanies that belongs to the Central and h3 16 Southwest.
17 Q.
At any rate, during the time that they 18 were interconnected and operating in interstate 19 commerce, you're not aware of the Public I
20 Utilities Board having sought suppliers of power j
21 outside the State of Texas?
j 22 A.
No.
No, we did not.
h3 23 0
It a v e you or the Public Utilities Board l
1 24 ever identified any interstate sources of power 25 that you would have purchased but for the 1
ROUNDTREE 1
the lottor ocyc what you ooy, Mr. Dnidwin.
2 Q
Mr. Roundtree, have you hap occasion since 3
y u came to the Public Utilities Board to 4
study the. question of the interconnection 5
f ERCOT and the Southwest Power Pool?
6 A
No, sir.
{
7 0
Have you directed that that be done by any 8
person on your staff?
9 A
Yes.
I have asked when Mr. Gallick arrived, 10 I informed Mr. Gallick that in his capacity 11 as the associate manager of engineering and P anning that we did want to participate l
12 13 fully in the activities of ERCOT and that we 14 wanted to be a member and participate in the 15 tis.
You know, any detailed testimony of his 16 1.nterface with either organization.or not 17 not would have to come from him.
I would 18 have no knowledge.
19 0
I probably misstated the question.
.What I 20 was asking about, whether you or some member 21 of your staff had studied the question of l
22 electricity, in synchronous operation of
)
23 ERCOT and the Southwest Power Pool.
24 A
I didn't understand the question.
I have not 25 directed anyone to do that..
9
l ROUNDTREE 167 1
0 You don't hevo any know1cdga on that oubjoct?
{_
2 A
No.
TL 3
0 Have you read the PTI report?
4 A
No, sir.
5 o
Do you know what I'm talking about?
l 6
A Yes, I think Gallick showed~it to me one 7
time, but I don't get involved in that.
8 0
I believe that it's true, is it not, that m
^
9 the Public Utilities Board is not seeking or FL lo is not interested in participation in the s
11 Ccmanche Peak nuclear project?
I 12 A
I don't believe participation has been 13 eliminated but I am aware of no overt moves E
14 that we have made toward a move in Comanche l
15 Peak, Mr. Baldwin.
1 16 0
At any rate, the Comanche Peak is not men-E 17 tiened in this Burns and MacDonald report, 18 is it?
l 19 A
I don't believe that it is.
You know, I l
20 would hasten to add that the recommendations 21 of the staff, of course, are not limited to 22 the recommendations contained in the Burns 23 and MacDonald report.
24 Q
Have you studied the Comanche Peak?
g 25 A
I have not asked anyone to really look at 1
i
F' LIZKA 163
[_
1 in the minutes?
2 A
I believe so, t
I 3
Q Now, w as it your understanding at the time H
4 you left the Public Utilities Board that tis was operating in intrastate or inter-5 l
6 state commerce?
7 A
When I left?
8 0
Right.
l 9
A Before I left my understanding was that it f
10 was interstate.
In
'78, I don't know.
E 11 Q
You don't know whether it was still inter-12 state or whether it had gone back to intra-l 13 state?
14 A
No, I don't know.
15 Q
Didn't make any difference to you one way f
16 or the other?
l l
1 17 A
No.
18 Q
Did the board, while you were there, j
19 autho rize PUB intervention in the South Texas 20 Project proceeding before the Nuclear 21 Regulatory Commission?
22 A
I don't remember.
23 Q
You don't remember whether it was presented 24 to you or what was said about the proceeding?
I.
25 A
I really don't remember.
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SepterLcr 19, 1900 MCt.'5*tCs LIGHTI:40
- f. N.fl;E COF.FhnY (CCW/Lif<.C)
- x. Cecree Spiege1 Epicsol E McDiarrid 260G Virgit.ia Avenue, !!.W.
Washington, D.C. 20037 06ar Goorget Ycur stater, ants at the Septe:icr 15 rrwhearir.g conference lead r e to conclude that you intend to put on a cau against my client in hovn=ber.
Ir. rf letter to you of August IS I suggestud a schedule for our trial preparation, but you declined to answer.
I W I r. cst ir.aist that we begin trici preparation as soon as possibic.
I propose the fellcting schedcle for your con-sideration:
1.
September 26:
Exchange trial estitits to begin procect of stipulation as to authenticity and foundation proof.
2.
Septer:1.sr 29 :
Exchange preliininary scote:wnt of issues and propcced stipu-lations of fact.
3.
October 1:
a ct to discusa stipulations of fact and identify areas of cisagrecrent.
4.
October 3:
.%et to agree on statecent cf issues to be providad to the Lcard.
j
Mr. George cpiegel Septec:t.ar 19, 1500 Please call a as quickly as pc==ihle te diccuss this proposed schedule.
Very truly yours, J. Gregory Ccpeland JCC:62 CO Mr.
Y.. D. CEZ:pciff Mr. Joscph EDCLtG bc:
Mr. Jon Wood tir. Richard Ealough Mr. Ion Douknight Mr. Doug Green Mr. Mike Baldwin
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H-1706-10P September 19, 1980 HOUSTON LIGS. TING
& POLER COMPANY (CSW/NRC)
Mr. George Spiegel Spiegel & McDiarmid 2600 Virginia Avenue, N.W.
Washington, D.C. 20036
Dear George:
In Doug Green's letter to you of June 2, 1980, he memorialized the agreement between PUB and EL&P to defer the depositions of Dr. Wilson and Mr. Mayben to a mutually convenient time in the future that would not conflict with the process of negotiations.
Your refusal to join the other parties in settling this case means that we must prepare for litigation.
Consequently, I propose that we schedule the depositions of Messrs. Wilson and Mayben to begin on October 7 and 9; respectively.
I would remind you that well before the commencement of Dr. Wilson's deposition I expect to have received the documents ordered produced by the Licencing Board on April 9, 1980.
/
With a hearing date in November, time is now of the essence in our trial preparation.
Consequently, if I have not received a confirmation or other suggested dates from you within a week, I intend to move the Licensing Board for an order compelling these depositions on the dates
. Indicated.
Therefore, I hope that you can call me at your earliest convenience concerning this matter.
Very truly yours, J. Gregory Copeland JGC:82 l'
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!!r. M. c. ?stgels Mr. Joseph hotts bc:
Mr. Jon Wood Mr. Eichard Balough Mr. Ion Bouknight Mr. Doug Green Mr. Mike Ealdwin i,
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uw OFFICES SPIEGEL & McDI ARMID eONNIE S. BLAIR
.it Or.GE SPIEGE L. P C.
ROBERT MARLEY BEAR note AT c. McDIARuiD 2600 VIRGINIA AVENUE. N.W.
9ANDRA J STRE8EL THOMAS C. TRAUGER se01E RT A. JABLON WASHINGTON. D.C. 20037 JOMN MICHAEL ADRAGNA EMES N. MORWOOD CYNTM1 A S. BOGOR AD TELEPHONE (2021333 4500 GARY J. NEWELL AL AN J ROTH eNAPvCES E. FRANCIS M ARC R. PolRIE R I
ELECOPIER (202) 333 2M4 M ARTA A. M ANILDI DANIEL 1, D AVIOSON 1HOM AS N McMUGH, JR.
JOSEPH L. VAN E ATON DANIEL J GUTTM AN STEPHEN C. N6CMOLS u TER < M ATT September 25, 1980 DAVID R ST R AU S 08 COUNSEL LLOYD E. DIETRICH J. Gregory Copeland, Esq.
Baker & Botts One Shell Plaza Houston, Texas 77002 Re: NRC Dockets 50-498A, 50-499A (South Texas);
50-445A, 50-446A (Comanche Peak)
Dear Gregory:
This responds to your letters of September 19, 1980 regarding the supplemental interrogatories to Brownsville and a proposed schedule for trial preparation.
We believe these matters are premature until there is (i) com-pletion of the concents due to the NRC Trial Board today concerning the proposed settlement, and (ii) consideration of the procedures which may result if the concerns of Brownsville and perhaps others cannot be dis-posed of by negotiations.
Please do not hesitate to call me regarding this matter.
Very truly yours,
/
George Spiegel GS/nzb cc:
Mr. M. D. Sampels Mr. Joseph Knotts l
l l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
HOUSTON LIGHTING & POWER
)
COMPANY, et al.
(South
)
Docket Nos. 50-498A Texas Project, Units 1
)
50-499A and 2)
)
)
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
(Comanche
)
Docket Nos. 50-445A Peak Steam Electric Station,
)
50-446A Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing:
l RESPONSE OF HOUSTON LIGHTING AND POWER COMPANY TO MOTIONS OF THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE FOR DISAPPROVAL OF NEGOTIATED LICENSE CONDITIONS AND FOR DELAY IN COMING FORWARD WITH EVIDENCE AND BRIEFS were served upon the following persons, by hand *, or by deposit in the United States Mail, first class postage prepaid, this
)
7th day of October, 1980.
s',/
l' k,ha
I Alan S. Rosenthal, Chairman
- Jon C. Wood, Esquire Atomic Safety & Licensing Appeal Matthews, Nowlin, Macfarlane
& Barrett Board Panel U.S. Nuclear Regulatory Commission 1500 Alamo National Building Washington, D.C.
20555 San Antonio, Texas 78205 Charles G. Thrash, Jr., Esquire Thomas S. Moore Atomic Safety and Licensing Appeal E.W. Barnett, Esquire Theodore F. Weiss, Esquire Board Panel U.S. Nuclear Regulatory Commission J. Gregory Copeland, Esquire Washington, D.C.
23555 Baker & Botts 3000 One Shell Plaza Michael C. Farrar
!!ouston, Texas 77002 Atomic Safety & Licensing Appeal R. Gordon Gooch, Esquire Board Panel.
U.S. Nuclear Regulatory Commission Steven R. Hunsicker, Esquire Washington, D.C.
20555 Baker & Botts 1701 Pennsylvania Avenue Marshall E. Miller, Chairman Wc.=hington, D.C.
20006
- Atomic Safety & Licensing Board
- Frederic D. Chanania, Esquire Panel U.S. Nuclear Regulatory Commission Michael B.
Blume, Esquire Washington, D.C.
20555 Ann P. Hodgdon, Esquire U.S. Nuclear Regulatory Commission
- Michael L. Glaser, Esquire Washington, D.C.
20555 1350 17th Street, N.W.
Washington, D.C.
20036 Roff Hardy Chairma-and Chief Executive Sheldon J. Wolfe, Esquire Officer
- Atomic Safety & Licensing Board Central Power and Light Company Post Office Box 2121 Panel U.S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D.C.
20555 G.K. Spruce, General Manager Atomic Safety and Licensing City Public Service Board Post Office Box 1771 Appeal Board Panel U.S. Nuclear Regulatory Commission San Antonio, Texas 78203 Washington, D.C.
20555 Mr. Perry G. Brittain
- Chase R. Stephens, Supervisor (20)
President Docketing and Service Branch Texas Utilities Generating Company U.S. Nuclear Regulatory Commission 2001 Bryan Tower Washington, D.C.
20555 Dallas, Texas 75201 Mr. Jerome D.
Saltzman G.W.
Oprea, Jr.
Chief, Antitrust and Indemnity Executive Vice President Houston Lighting & Power Company Group U.S. Nuclear Regulatory Commission Post Office Box 1700 Washington, D.C.
20555 Houston, Texas 77001
- J.
Irion Worsham, Esquire R.L. Hancock, Director Merlyn D. Sampels, Esquire City of Austin Electric Utility Post Office Box 1086 Spencer C. Ralyea, Esquire Worsham, Forsyth & Sampals Austin, Texas 78767 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201
, Kenneth M. Glazier, Esquire Don R.
Butler, Esquire David A.,Dopsovic, Esquire 211 East Seventh Street Frederick H. Parmenter, Esquire Austin, Texas 78701 Susan B. Cyphert, Esquire Nancy A. Luque, Esquire Mr. William C. Price Robert Fabrikant, Esquire Cantral Power & Light Company Energy Section Antitrust Division Post Office Box 2121 U.S. Department of Justice Corpus Christi, Texas 78403 P.O. Box 14141 Washington, D.C.
20044 Mr. G. Holman King West Texas Utilities Company Morgan Hunter, Esquire Post Office Box 841 Bill D. St. Clair, Esquire Abilene, Texas 79604 McGinnis, Lockridge & Kilgore Fifth Floor Jerry L. Harris, Esquire Texas State Bank Building Richard C.
Balough, Esquire 900 Congress Avenue city of Austin Austin, Texas 78701 Post Office Box 1088 Austin, Texas 78767 W.S. Robson General Manager
- Joseph B. Knotts, Jr., Esquire South Texas Electric Cooperative, Nicholas S. Reynolds, Esquire Inc.
C. Dennic Ahearn, Esquire Route 6, Building 102 Debevoise & Liberman Victoria Regional Airport 1200 Seventeenth Street, N.W.
Victoria, Texas 77901 Washington, D.C.
20036
- Robert C. McDiarmid, Esquire Don H. Davidson George Spiegel, Esquire City Manager Robert A. Jablon, Esquire City of Austin Marc R. Poirier, Esquire P.O.
Box 1088 Spiegel & McDiarmid Austin, Texas 78767 2600 Virginia Avenue, N.W.
Suite 312 Jay Galt, Esquire Washington, D.C.
20037 Looney, Nichols, Johnson & Hays 219 Couch Drive Leon J. Barish, Asst. Atty. General Oklahoma City, Oklahoma 73102 Texas Attorney General's Office Post Office Box 12548 Knolant J.
Plucknett Aust:n, Texas 78711 Executive Director Committee on Power for the South-
- William H. Burchette, Esquire west, Inc.
Frederick H. Ritts, Esquire 5541 East Skelly Drive Law Offices of Northcutt Ely Tulsa, Oklahoma 74135 Watergate 600 Building Washington, D.C.
20036 John W. Davidson, Escuire Sawtell, Goode, Davidson & Tioili Tom W. Gregg, Esquire 1100 San Antonio Savings Building Post Office Box Drawer 1032 San Antonio, Texas 78205 San Angelo, Texas 76902 oDouglas F. John", Escuire Leland F. Leatherman, Esquire McDermott, Will and Emery McMath, Leatherman & Woods, P.A.
1101 Connecticut Avenue, N.W.
711 West Third Street i
Suite 1201 Little Rock, Arkansas 72201 Washington, D.C.
2003,6
a 1 Paul W.
Eaton, Jr., Esquire Hinkle, Cox, Eaton, Coffield & Hensley 600 Henkle Building Pact Office Box 10 Rocw311, New Mexico 88201 Robert M. Rader, Esquire Connzr, Moore & Corber 1747 Pennsylvania Avenue, N.W.
W3chington, D.C.
20006 W.N. Woolsey, Esquire Kleberg, Dyer, Redford & Weil 1030 Petroleum Tower Corpus Christi, Texas 78474 Donald M. Clements, Esquire Gulf States Utilities Company Post Office Box 2951 Coaumont, Texas 77704 Dick Terrell Brown, Esquire 800 Milam Building Sen Antonio, Texas 78205 Robert E. Cohn, Esquire Richard J. Leidl, Esquire Butler, Binion, Rice, Cook
& Knapp 1747 Pennsylvania Avenue, N. W.
Ninth Floor Washington, DC 20006 StGphen H. Lewis, Esquire U. S. Nuclear Regulatory Commission i
Office of the Executive Legal Director 1
Washington, DC 20555 Robart A. O'Neill, Esquire f
Millor, Balis & O'Neil, P.C.
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776 Executive Building
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1030 Fifteenth Street, N.W.
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Washington, D.C.
20005 v
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