ML20052B632

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Application for Issuance of Civil Subpoena Duces Tecum Directed to B Stephens Re Interpretation of Current Contract Between Az Municipal Water Users Assoc & Util & Status of Renegotiation.Related Correspondence.W/Certificate of Svc
ML20052B632
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/26/1982
From: Bernabei L
HARMON & WEISS, HOURIHAN, P.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20052B624 List:
References
NUDOCS 8205030390
Download: ML20052B632 (8)


Text

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UNITED STATES OF AMERIC A NUCLEAR REGULATORY COMMISSION

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" : ;p y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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ARIZONA PUBLIC SERVICE

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Docket Nos. STN 50-528 COMPANY, ET AL.

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STN 50-529

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STN 50-530 (Palo Verde Nuclear Generating ))

Station, Units 1, 2 and 3)

APPLICATION FOR ISSUANCE OF CIVIL SUBPOENA EUCES TECUM Intervenor Patricia Lee Hourihan, by her attorney, applies to the Atomic Safety and Licensing Board for the issuance of a Civil Subpoena Duces Tecum to:

Bill Stephens Arizona Municipal Mater Users Association 1010 East Jefferson Street Phoenix, Arizona 85034 for the purpose of requiring the above-named individual to give testimony pursuant to sec", ion 2.720 of the Commission's regulations.

A copy of the pror osed Civil Subpoena is attach-ed hereto.

The testimony which Intervenor seeks to have Mr. Stephens testify about is his interpretation of the current contract between the Arizona Municipal Water Users Association and the Applicants and the status of renegotiation of that con-tract.

't!HEREFORE, Intervenor respectfully requests that the Chairman of the Licensing Board issue a Civil Subpoena Luces T cum in the form attached hereto directing Mr. Stephdus to appear and give testimony.

8205030390

Respectfully Submitted, 7

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DA.n u i

Lynn Bernabei fiarmo

& Weiss 1725: ' I" S treet, N.W.

Suite 506 Washington, D.C.

20006 (202) 833-9070 Dated:

April 26, 1982 l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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)

ARIZONA PUBLIC SERVICE

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Docket Nos.

STN 50-528 COMPANY, ET AL.

)

STN 50-529

)

STN 50-530 t (Palo Verde Nuclear Generating )

Station, Units 1, 2 and 3)

)

SUBPOENA DUCES TECUM (CIVIL)

The Nuclear Regulatory Commission and Robert M. Lazo, Chairman, Atomic Safety and Licensing Board, to:

Philip Shea, Esquire, MARKS, SHEA & WILKS, 114 West Adams, Suite 200, Phoenix, Arizona 85003 YOU ARE HEREBY COMMANDED to appear and give your testi-mony in a hearing, on Wednesday, April 28, 1982 at 10:00 a.m.,

in Hearing Room 4 of the Seventh Floor, Federal Building, 230 North First Avenue, Phoenix, Arizona.

You have been subpoenaed by Patricia Lee Hourihan, In-tervenor, in the above captioned matter.

Pursuant to the Commission's regulations at 10 CFR 2.720 (f), on motion made by you promptly, and in any event on or before 10:00 a.m. April 28, 1982, and on notice to attorney for Intervenor, the Chairman of the Atomic Safety and Licensing Board, 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.

You are hereby notified that any failure to obey this subpoena may be deemed a contempt and appropriate sanctions may be ordered.

DATED this day of April, 1982.

ATOMIC SAFETY AND LICENSING E0ARD By Robert M. Lazo Chairman

JNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THF ATORIC SAFETY AND LICENSING BOARE In the Matter of

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)

ARIZONA FUBLIC SERVICE

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00FPANY, ET AL.

Docket hos. STN 50-528 STN 50-529 STN 50-530 (Palo Verde Nuclear Generating ))

Station, Units 1, 2 and 3)

SUBF0ENA LUCES TECUM (CIVIL)

The Nuclear Regulatory Commission and Robert M. Lazo, Chairman, Atomic Safety and Licensing Board, to:

Bill Shephens, Arizona Municipal Matbr Users Association, 1010 East Jefferson Street, Phoenix, Arizena 85034.

YOU ARE HEREBY COMMANEED to appear and give your testi-mony in a hearing, en Wednesday, April 28, 1982 at 10:00 a.m.,

in Hearing Room 4 of the Seventh Floor, Federal Building, 230 North First Avenue, Phoenix, Arizona.

You have been subpoenaed by Patricia Lee Hourihan, In-tervenor, in the above captioned matter.

Pursuant to the Commission's regulations at 10 CFR 2.720 (f), on motion made by you promptly, and in any event on or before 10:00 a.m. April 28, 1982, and on notice to attorney for Intervenor, the Chairman of the Atomic Safety and Licensing Board, 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.

4 You are hereby notified that any failure to obey this subpoena may be deemed a contempt and appropriate sanctions may'be ordered.

DATED this day of April, 1982.

ATOMIC SAFETY ANE LICENSING BOARD By Robert M. Lazo Chairman e

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O-United States of America Nuclear Regulatory Commission Before the Atomic Safety and Licensine Board J f/.L

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t In the Matter of

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ARIZONA ?UELIC SERVICE

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Docket Nos. STN 50-528 COMPANY, et al

)

STN 50-529-STN 50-530 (Palo Verde Nuclear Generating

)

Station, Units 1, 2 and 3)

)

)

Certi ficate of Service I hereby certify that copies of Intervenor's Supplemental Response to Intervenor's Response to Joint Applic, ants' Request for Admissions, Application for Issuance of Civil Subpoena Duces Tecum (to Philip Shea), Application for Issuance of Civil Subpoena Duces Tecum (to Bill Stephens), Motion of Intervenor to add New Contentions or Alternately Amend Her Current Contention on Inadequate Assurance of Water, have been served on the following individuals by deposit in the U.S. Mail, properly addressed and wi th po6tage prepaid, this 26th day of April, 1982.

Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.O, 20$$$

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20$$$

  • Robert M.

T, azo, Esq.

Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555

.Dr,' "hichard F.

Cole Atomic Safety and Licensing Board

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U,5.

"uclear Regulatory Ccamissicn

  • ashington, D.C.

20555

  • D r.

Dixon Callahan Union Carbide Corporation F.O.

Box Y Oak 0.idge, TN 37830

  • Lee Scott Dewey, Esq.

Office of the Exe~cutive Legal Director U.S.

Nuclear Regulatory Commission

'da s hi ng to n,

D.C.

20555

  • Arthur C.

Gehr, Esq.

Charles Bischoff, Esq.

Snell and Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 Rand L.

Greenfield Assistant Attorney General P.O.

Drawer 1508 Santa Fe,New Mexico 87504-1508 Atenic Safety and Licensig Board Anneal Panel U.S. Nuclear Regulatory Commission ^^

Washington,D.C. 20555 1

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-a Lyqne Bernabei V

  • hand delivered