ML20096D773

Forwards Notice of Deposition & Subpoena Duces Tecum to C Allen,For Signature.Requests Signature as Soon as Possible So Papers May Be Served at Earliest Practicable Date.Related Correspondence

ML20096D773
Person / Time
Site:	Comanche Peak
Issue date:	09/01/1984
From:	Downey B BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bloch P, Grossman H, Jordan W Atomic Safety and Licensing Board Panel
References
OL-2, NUDOCS 8409060291
Download: ML20096D773 (7)

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' LAW OFFICES OF BISHOP, LIBERMAN, COOK PURCELL & REYNOLDS 1200 S EVENTE ENTH STR E ET, N. W. IN NEw yORM WASHINGTON, D. C. 2 0036 BISHOP, LIBERMAN & COOK (202) 857-9800 26 BROADWAY NEW YORM N EW YO R M 10004 TELEX 440574 INTLAW Ul (212)248-6900 TELEX 222767 8 1984

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Peter B. Bloch, Chairman { lie'rbert Grossman, Esq.

Atomic Safety and Licensing Atomic Safety and Licensing Board Board U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Mr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Re: et al.

Texas (Comanche Utilities Peak Electric Stean Company, Electric StatIon Units 1 and 2), Docket Nos. 50-445-2 and 50-446-2 Gentlemen:

Enclosed please find notice of deposition and subpoena duces tecuin which the Applicants wish to serve on Cory Allen.

Please sign the subpoena as soon as possible so that we can serve these papers on Mr. Allen at the earliest practicable date.

Counsel for the Applicants may file a motion to reconsider the Board's decision to call Mr. Allen as a witness. If such a motion is filed, we will try to file it by the close of business l

on Tuesday, September 4.

Sincerely,

// /

Bruce L. Downey Enclosures (1) Notice of Deposition ,

(2) Subpoena ,/

cc: Service List 8409060291 840901 PDR ADOCK 05000445 Q PDR

Enitch 9tates of America NUCLEAR REGULATORY COMMISSION O

In the matter of:

TEXAS UTILITIES GENERATING COf*PANY, et al.

Comanche Peak Steam Electric Station, >- DOCKET NO. 50-445 and Units 1 and 2 50-446 TO (Applicction for Operating Licenses)

Mr. Cory Allen 1102 Columbia Houston, Texas .77708 YOU ARE HEREBY COMMANDED to appear ..f9.r...a...Q.e.pgs,it.i,g,g,,bef,9re,, a,n

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in the et' ty o f . ....H..o. .u. . .s.t..o.n..,.. T.e. x.a...s.... a. t. ..t. h.e.....F i.r. s..t....C..i..t..y T...o.w..e..r.... .. .. .. . . .

on the... . 6 t.h .. .. day o f...S.9Ete,m,b,er, ,,,,, ,19,,,,8,,4....a t.. ...l.0,,;,0.9...... 0' clock A. M.

to testify o n behalf o f ... ..... .. .... ........ ... ....... .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

in the abose entitled action and bring with you the document (s) or objectis) described in the attached schedule.

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l BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD BY l

Bruce L. Downey Texas Utilities

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l NnTEad!bg Company -

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TELEPHONE 10 C.F.R. 2.720 (f) pres, ding ofpcar or, if he is unvassable. the On motion made promptly, and in any event. Commisaon may (i) quash or modify the sub-at or before the time specified in the arbpoena poena if it is unreasonable or requires evidence for compliance by the person to whom the sub- not relevant to any matter in issue, or (2) con-90ans is dWed. and on notice to the party at dition dennes of the motion on lust and reasonable ,

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

) Docket Nos. 50-445-2 and TEXAS UTILITIES ELECTRIC ) 50-446-2 COMPANY,'ET AL. )

) ( Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

SCHEDULE OF DOCUMENTS To: Mr. Cory Allen

-1102 Columbia Houston, Texas 77708

1. All reports, memoranda, letters, charts, and any other documents in your possession which were removed from Comanche Peak;

2. -With respect to your employment at Comanche Peak,all memoranda, diaries, letters and other written recordings of_ events at Comanche Peak; all correspondence and other recorded exchanges to and from the Government Accountability Project, and the Trial Lawyers for Public Justice, including, but not limited to, all statements and transcripts of statements; all correspondence and other recorded exchanges to and from the Nuclear Regulatory Commission, including, but not limited to, all statements and transcripts of 2 a --

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statements; and all tape recordings of conversations in l

your possession regarding Comanche Peak regardless of l whether they were recorded by you or another individual;

3. With respect to your current employment at the South Texas Project Electric Generating Station, all i

memoranda, diaries, letters and other written recordings of events at the South Texas Project; all correspondence and other recorded exchanges to and from the. Government Accountability Project and the Trial ,

Lawyers for Public Justice, including, but not limited 1

to, all statements and transcripts of' statements; all correspondence and other recorded exchanges to and from the Nuclear Regulatory Commission, including, but not  !

limited to,.all statements and transcripts of statements; . and' all tape recordings of conversations in your possession regarding the South Texas Project regardless of whether they were recorded by you or another individual.

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

) Docket Nos. 50-445-2 and TEXAS UTILITIES ELECTRIC ) 50-446-2 COMPANY, ET AL. )

) ( Application for (Comanche Peak Steam Electric ) Operating License ~s)

Station; Units 1 and 2) )

NOTICE OF DEPOSITION To: Mr. Cory Allen 1102 Columbia Houston, Texas 77708

.You are hereby notifie'd that Texas Utilities Generating

. Company will take your oral deposition commencing on Thursday, September 6, 1984, at 10:00 a.n.' and continuing until completed.

The deposition will' be taken at the offices of Vinson & Elkins, First City Tower, Houston, Texas, 77002.

The deposition will relate to allegations made in connection with contention five of the Citizens Association - For Sound Energy relating to harassment, intimidation and threats of quality-control' personnel during construction activities at the Comanche

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Peak Steam Electric Station.- Accordingly, you should be prepared to answer questions as to the date, location and circumstances of each of such allegations of which you have knowledge. You should also bring ' with you the following:

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1. All reports, memoranda, letters, charts, and any other documents in your possession which were removed from Comanche Peak;

-2. . With respect to your employment at Comanche Peak,all memoranda,-diaries, letters and other-written recordings of events at Comanche Peak; all correspondence and other recorded exchanges to and from the Government Accountability Project, and the Trial Lawyers for.Public Justice, including, but not limited to, all statements and transcripts of statements; all correspondence and other recorded exchanges to and from the. Nuclear Regulatory Commission, including, but not.

limited to, all statements and transcripts of.

statements; and all tape recordings of-conversations in your possession regarding Comanche Peak regardless of whether they were recorded by you or another individual;

3. With respect to your current employment at the South Texas Project Electric Generating Station, all memoranda, diaries, letters and other written recordings of events at the South Texas Project; all correspondence and other recorded exchanges to and from

-the Government Accountability Project and the Trial Lawyers for Public Justice, including, but not limited to, all statements and transcripts of statements; all correspondence and other recorded exchanges to and from e,

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. .the-Nuclear Regulatory Commission, including, but not limited to, all statements and transcripts of statements; and all tape recordings of conversations in your. possession regarding the South Texas Project regardless of whether they were recorded by you or another individual.

The' deposition will.take place before an Offi ial Court Reporter.

Bruce L. Downey BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9800

-September 1, 1984

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