ML20024E562
| ML20024E562 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/08/1983 |
| From: | Berwick B TEXAS, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20024E563 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8308150302 | |
| Download: ML20024E562 (3) | |
Text
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NTED ConHEenvnew UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00gEjED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'83 AUG 12 P4:08 In the Matter of S
S 0FFnE OF SECRETA:
HOUSTON LIGHTING & POWER S
Docket Nos00CggTy{ g gv!U COMPANY, ET AL.
(South Texas Project, Units S
1 and 2)
S STATE OF TEXAS'S REQUEST FOR SUBPOENA OF QUADREX CORPORATION The State of Texas has filed its Notice For Deposition of Quadrex Corporation on Written Interrogatories.
The undersigned has attempted to get in touch with officers of the corporation to discuss possible appearance by agreement The corporation's general counsel has responded, but as yet not with any specific agreement.
Therefore the State believes it is necessary for the corporation to be subpoenaed.
The State contends that the questions proposed to be posed to Quadrex are highly relevant to the Phase II issues before the Board.
Various Bechtel, Brown & Root, and NRC documents have commented on the Quadrex report and have cast some doubt upon its conclusions and the bases therefor.
To resolve disharmonies
[3 among these various documents, Quadrex's own testimony is
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. ' in necessary.
The State incorporates by reference its Notice For Deposition and Exhibit 1 thereof.
The questions comprising Exhibit 1 by their own terms indicate relevancy.
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The State requests that the Board issue a subpoena requiring the Quadrex Corporation to appear and sit for a deposition via a person or persons with knowledge of the facts inquired about.
The State requests that the time and place and officer mentioned in the subpoena be as stated on Exhibit l
1 attached hereto, and that the Corporation be required to produce at the deposition all documents and tangible things identified in the questions comprising Exhibit 1 to the Notice For Deposition.
Respectfully submitted, JIM MATTOX Attorny General of Texas DAVID R.
RICHARDS Executive Assistant Attorney General JIM MATHEWS Assistant Attorney General Chief, Environmental Protec*. ion Division
^54u 5 Awk BRIAN E.
BERWICK (SBN 02258500)
Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 78711 l
(512) 475-4143 i
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e Exhibit l The deposition officer will be Valerie A.
Fitch.
This person is a certified shorthand reporter and notary public in and for the State of California, County of Santa Clara.
This person's work address and the place where the deposi-f tion will be taken, are:
586 North First St.
Suite 240 San Jose, CA 95112 f
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