ML20244A811

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Partially Withheld Transcript of Ld Howard 840720 in Camera Deposition.Pp 1-23
ML20244A811
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/20/1984
From:
Atomic Safety and Licensing Board Panel
To:
Shared Package
ML20097F079 List:
References
FOIA-84-487 NUDOCS 8906120156
Download: ML20244A811 (25)


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UNTTED STATES OF AMERICA NUcL2Aa REctLArosy CoMM ss!on (g h Bb

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3 la the matter of:

TEXAS UTILITIES ELECTRIC COMPANY, ee al Docket No. 50-445 (Coma;'.che Peak Steam Electric 50-446 Station, Units 1 & 2)

IN CAMERA SESSION Deposition of: Larry D. Howe.rd DOT

. L*88 tion:

Glen Rose,- Texas Pages: - 23 fz; Date: Friday, July 20, 1984-fItt -

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IN CAMERA 1

mg -I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I

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BEFORE THE ATOMIC SAFETY & LI CENS ING E,0 AR D 4

1 5

~x In the matter of:

i 6

  • ~

TEXAS UTILITIES ELECTRIC 7

COMPANY, et cl.

Docket t;o s. 50-445 8

50=446 (Comanche Peak Steam Electric n

Station, Units 1 and 2)


x 10 II Glen Rose Motor Inn Glen. Rose, Texas 33

. July 20, 1984 14 Discovery Deposition of:

LARRY D.

HOWARD (IN CAMERA),

15 called for examination by counsel for the Applicants, 3,

taken before Marilynn htions.

Court Reporter,

,7 is beginning at 7:45a.m., pursuant to agreement.

19 i

20

]

21 22 l

23 i

24 I l 25 i

2 mgc-2 1

APPEARANCES:

2 On behalf of the Applicants Texas Utilitias E),ectric

~~~

Company, et al.:

3 BRUCE DOFt?%Y, ESQUIRE d

Phhop, Libernan, Ceok,-Purcell 6 Reynolds 1: 00 Sever.teenth Street, Northwest

?

i Woohington, D.C.

20036 6

On oeSalf of the Nuclear Regulatory Commission Staff:

7 GEARY S.

MIZUNO, ESQUIRE Office of the Executive Legal Director 8

U.S.

Nuclear Regulatory Commission Washington, D.05

-20555 9

On behalf of the Intervenor Citizens Association for.

10 Scund Energy:

o 11 MS. b1LLIE CARDE Law Clerk 12 Trial Lawyers for Pub 11% Justice 2000 P Street, Northwest, Suite 611 13 Washiutton, D.C.

20036 to 15 16 17 IB 19 20 21 22 23 24 25

3 mgc-3 1

I_ N_ D_ E_ X, 2

WITNESS:

EXAMINATION BY:

3 LAERY D.

HOWARD MR. DOWNEY:

4 MR. MIZUNO:

20 a

MS. GARDE:

21

-5 6

7 8

9 10 11 12 13 14 15 No Exhibits.

16 17 18 19 20 21 22 I

23 l

24 25

4 mn2pbl 1

P 3 g [ { E p,1 E g 1 2

Whereupon, i

3 LARRY D.

HOWARD I

4 a witness, was called for examination and, having been 5

previously duly sworn, was e::ami n e d and testifiej further 6

as follows:

7 EXAMINATION 8

EY MR. DOWNEY:

9 Q

Mr Howard, on what date were these events 10 that you've just described in your direct examination?

?

11 A

I couldn't tell you the'date.

12 Q

What was the approximate date?

l 4

13 A

Somewhere between the second'and third week le in December is the best I re membe r.

I 15 Q

Sometime around Christmas time.

16 A

Probably, yes.

17 Q

And that was 1983.

IE A

Right.

19 Q

What was your job at the time?

20 A

My job was electrical technician.

I helped 1

1 21 in the field work directly underg supervision.

f 22 Q

And which trailer did thi, conversation occur?

e~

i 23 A

In the trailer where ffice was.

24 Q

And you say you were sitting about four feet 25 from his desk?

'5 2pb2 I

i 1

A Right.

+

I 2

Q Were you talking to when these-fj 1

3 unknown gentlemen walked in?

l 4

A Yes, I'm sure that we were carrying on some.

5 kind of a conversation.

=

-1 6

Q And you say someone from TUGC0 came in.

7 A

Right.

8 Q

Do you. recall his name?

9 A

No, sir I don't.

' l 10 Q

Was he alone or.was he with someone?-

11 A

there was another fellow with him.

12 Q

Do you recall his name?

13 A

No, I don't.

l 14 Q

And they walked in between you and j

- j 15 is that right?

f l

16 A

Right.

H 17 Q

And were you seated at this time?

18 A

Yes, sir.

I i

19 Q

Did they remain standing?

)

20 A

Yes. sir.

21 Q

You testified that they wanted him to sign j

22 some documents.

Did they have the documents'with them when 23 they arrived?

9

.,i 24 A

No, had the' document.

Vj 25 Q

And did you review those documents?

l l

il 6

i t

1 A

No, I didn't.

1 2

Q So you never saw the' documents.

3 A

I seen them.

We were working in-the battery

~

4 room at the time.

5 Q

Did you read over the documents that'they 6

wanted him to sign?

7 A

No. I didn't.

8 Q

Do you have any' firsthand knowledge strike-9 that.

10 Did they indicate specifically~which documents 11 they wanted to sign?

i i

12 A

1 wouldn't-be sure.

They indicated to him j

i 13 which ones that they wanted him to sign, but I couldn't say 14 for sure that I knew.

15 Q

So you don't have firsthand knowledge of 16 what documents?

17 A

No, I do know what they were about, i

IB Q

Did they discuss what they were about?

)

-1 10 A

Yes.

I 20 Q

And what was it they discussed?

1 21 A

I believe it was cable separation violations.

1' 22 Q

Those are some kind of documents that are 23 cable separation violation?

24 A

No, no.

The document was some type of work l

25 order.

i i

i 4

1 i

7-i a

j 1

Q Work order for what?

What kind of work would

)

i 2

these documents have authorized?

I 3

I 3

A For them to go ahead and complete something j

)

4 down in the battery room.

I 5

Q To complete some kind of test?

l i

6 A

Right.

To turn this-piece-of equipment over.

7 Q

Would it be a work order to test!or a 8

work order to turn over?

(

9 A

I b >211 e v e i'c was a turn over.

10 Q

Is turn over a work order?

I 11 A

Well, I'll put it like this..

You have ce'rtainl

{

12 tests that you have to perform out there before you can turn 13 anything over.

Ve ran f. n t o a hitch on the cable s e p a r a t *. o n 14 violations.

I do not remember what procedures Iwenc

's 15 through to'gtt this completed, but this was what it was all

/}!

16 about.

It was because found a problem which he thought

  • 17 was a problem.

These other people did not think' it was a l

18 p r o b l e ts.

And myself, that was not my' business, that was l

19 This is just stuff that I know and.I overheard.

/'

y 20 0

In the back of these d o c u n.e n t s, were they 21 documents to perform certain tests?

That would have been the 3

22 effect of 1 signing these papers.

t y

kwasdoing 23 A

the tests.

t--

,e y

24 Q

And if he'd have signed these papers, would i

25 that have authorized others to start work?

l i

I i

t A

l'm not positive.

No, I don't know for sure.

2 Q

So it could have been a work order.

3 A

Right.

d Q

And it could have been a turn over document 5

of some sort?

6 A

Well, they would both coincide with the other.

7 Q

Are you sure about that?

8 A

Yes.

9 Q

You're sure that the documents to do work to is the same as the document to turn over hardware to the il client.

Are those the same documents?

k 12 A-Well, they have a lot of documents for turn j

't 13 over.

In other words, it could be anything.

You could have 14 15 or 20 documents to turn one piece of equipment-over.

And I

is if you don't have all of these, then you can't turn it over.

j t

16 Q

You have to complete certain tests before 17 you turn over; 1s that right?

i 18 A

Right.

19 MS. GARDE:

Mr. Downey, Mr. Howard's already f

20 testified he hasn't seen the documents, he isn't sure what 21 the documents were.

22 BY MR. DOWNEY:

23 Q

Is it your testimony, Mr. Howard, that you 24 don't know what the specific documents were that these j

i 25 unnamed people asked Mr. Howard to sign on some date in

=

j 1

I i

k i

i i

l 9

j j

1 December?

i

?

2 A

You mean{

J 3

Q You're Mr. Howard.

I apologize.,'

.J

\\

4 A

No, I couldn't.

It's been six months.

No, I) 5 I couldn't sit'here and swear to it, no.

6 Q

And this one unnamed man asked to 7

go ahead and sign the documents.

f 8

A That's correct.

9 Q

What was this feedback?

DO you know what s

y 10 meant when he said he was waiting for feedback 11 before he signed these papers?

12 A

No.

13 Q

You don't know what he meant by that?

I 14

.A W e 1., I know that he needed the phone call 15 that he made, he needed them to verify this violation that i

16 he had found.

17 Q

And were you there when he placed this phone 18 call?

19 A

1 was there when he was talking to the people.

20 Q

On the telephone?

21 A

Right.

22 Q

Do you know who it was he was talking to?

i 23 A

No, I don't.

24 Q

Do you know where they were located?

Were l

l 25 they are on-site?

(

l 1

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_ - - _ - - - - - - - - - - - - - - - - - - - - - - - - - ^ - ^ ^ - - ' ' ~ ^ - ~ - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ^ ~ ~ ~ ~ ^

10 I

1 A-No, they were not.

2 Q

How do you know that?.

s.

3 A

Because he made a long distance phone call to a

talk to them.

~l 5

Q Did you hear the name of'the person to whom 6

he was speaking?

7 A

Well, I don't remember the name, no. sir -

8 Q

Do you recall the substance of what he was 9

saying on the telephone?

10 A

Something about the cable' separation violations.

I 11 Q

You say the violations, Mr. Howard..What I

12 violations do you have reference to?

l 13 A

Well, they have certain procedures out there.

14 I don't remember the procedures. I don't know what che 15 procedures are.

I couldn't. set here and tell you.

But it's (

l 16 up to the engineer to find these defects.

I 17 When he finds them, he does not go ahead and i

18 let work go any further until he is satisfied in his mind 10 that these violations don't occur.

That's what i

20 was doing.

He was doing his job to the utmost.

l 3

21 Q

Now do you know if' had brought v

22 these problems, these procedure problems to the attention 23 of people on-site prior to this conversation-that you 1

2e overheard on some week in December 1983?

25 MS. CARDE:

I object.

Beyond the scope of l

11' i

i j

I I

his direct.

2 MR. DOWNEY:

This.is a discovery deposition, j

3 Ms. Garde and I think that this does 1

~

d MS. GARDE:

Mr. Downey, it's.7:36.

The witnesis 5

said when he got here he had to leave at 7:30.

How many

' l i

6 more questions do you have?

7 MR. DOWNEY:

I'have about five more minutes 8

worth of questions.

I wish to explore his knowledge'of 9

these matters and I think that's1a perfectly legitimate 3

10 line of inquiry in a discovery deposition.

l 11 t

i I will withdraw my last question and start

]

l over for expediency.

i 12 13 BY'MR. DOWNEY:

Id Q

ur. Howard, do you know whether. prior.to this l

l 15 conversation that you overheard, do you know whether 16 had brought his perceived deficiencies to the attention 1

of people on-site?

i 17 l

I 18 A

I don't remember, no.

i II I

e l'

Q So you don't know whether those had been I

i i

20 raised on-site prior to this morning when you heard this 21 conversation?

I I

22 A

I don't remember.

I couldn't-say-for sure, no; 23 i

Q Had he written an NCR on these perceived j

l 24 violations?

25 A

I couldn't answer that either.

I l

1 4

l 4

)

12 l

1 Q

Is it possible that these had been brought-2 to the attention of his supervisors and they had-made a 3

determination with respect to his perceived deficiencies?--

d A

Repeat the quest' ion, f

5 Q

Is it possible that.astof the time:you-j.

6 overheard this conversation that people on-site had these 7

matters brought to their attention and'they had concluded.

l l

B there wasn't a problem with thes e cable spread. matters?

j l

9 A

I have no idea what them people thought.

'l 10 Q

When you said these documents concerned 11 cable spread violations 12 A

Cable separation violations.

13 Q

Cable separation violations, exc"se me.

I'll l

Id withdraw that.

s.

9 15 You testified that said that he d

16 wasn't. satisfied w1th the procedure, is that the remark he t

17 made during this conversation?

I IB A

He wasn't fully satisfied because, the best t

19 1 remember was the way that he read the pro

' ares, then 20 we were in violation.

But they were still wanting to go l

21 ahead and pass it on.

In-other words,~ overlook it ~ and go 22 on about their business.

23 Q

Could it have been that the matter had already; 2d t

been brought to the attention of the proper authorities and i

25 they had determined that

' perceived problem-N l

1 l

i 4

l i

-- )

I 13

i l

l 1

wasn't a problem at all?

2 A

I have no idea.

3 Q

This TUCCO man, you said he was upset; is l

4 that right?

l 5

A He was irate.

I o

Q Was irate?

i j

1 7

A He was after the fellow come in there and B

talked to him like he was a dummy, which I don't feel like-9 he is.

10 Q

You think the fellow from IUGC0 was a dummy?

11 A

No.

12 Q

And so they exchanged harsh words over this 13 matter?

i I

l 14 A

Well, yes.

15 Q

And they both thought they were right?

16 A

Correct.

t I

17 Q

And did sign these documents?

I 18 A

To my knowledge, no.

10 Q

You say they left, the man from TUGC0 left; 20 is that right?

k 21 A

Right.

22 Q

And you testified that he went to an office I

23 of Art London; is that right?

I 24 A

That's correct.

i 25 Q

Where's Mr. London's office?

Is it in the i

l l

l l

i a

1) o-

.j 14 1j j,,

i 1

1 trailer where this conversation took place 9-i t.{

e 2

A It's in the trailer next to it, annexedEto 3

Q So he left, just left the trailer.

1 I

4 A

He left the one that was in.

.J 5

Q And he came back with Mr. London.

6 A

Right.

7 Q

SO you really don't know where he went, do y o u;?. '

i I 8

A Well, I'm going to say that he went to Art

' i 9

London's office, because that's where Art usually stays.

10 Q

But you didn't see him go to Mr. London's

'I office?

l 12 A

No, I seen him go around the corner heading I

13 that way.

14

-Q And he returned with Mr. London?

How long 15 was it before he came back?

}

l 16 A

I'd say approximately three to five minutes.

}

thing}(-

17 Q

And when they returned you said the same 18 happened all over; is that right?

i i

10 A

Just basically, yes, sir.

a 20 Q

They asked him to sign these unknown papers 21 and --

a i

22 A

No, they told him to.

23 Q

And he didn't do it though, did he?

24 A

To my knowledge, no, sir.

j 25 Q

Now who is Mr. London?

t

~

,q 1

A Hewas{

immediate supervitor.-

2 Q-For.whom does Mr. London vork?

a 1

3 A

I guess.TUCCO.

4 Q

And were there. harsh words exchanged inithe-5 second conversation?

6 A

Yes.

7 Q

'And Mr. X from TUGCO. raised.his voice end 8

raised his voice; isi that right?

9 A

Yes. sir.

/

10 Q

Did'they ask who it war he was 11 waiting to.hcar from before he signed these papers?

12 A

I don't remember, 1

7 13 Q

Do you' recall' saying he was'vaiting L-14 from a tall back from somebody off-site'-

1 15 A

Right.

t to Q

Do you recall him identifying who it was that l

17 he was waitingLto hear from?

18 A

No, I couldn't --

19 MS.-GARDE:

Asked and answered.

I 20 BY MR. DOWNEY:

1 1

21 Q

How you testified in this second. conversation 22 someone said, you're treading on thin ice; is that right?

l 23 A

Yes, you'~e walking on thin ice is basically r

2d the little phrase that they used.

l 25 Q

Your response to a different question that i

i

\\

i

-l

16 I

said w:lking on thin water Which was it, do you recall?

2 A

Well, you don't walk on thin water.

There's 2

phrases that a fellow uses.

One of the.m is either you're i

4 walking on thin ice or you're barely treading water.

Gne 5

or the other.

6 But what they said, one of them told him, s aid:

7 you're just walking on thin ice.

You know, in other words, B

you don't do chia. I'm going to have your j ob, Buster.

i 9

That's about the way I took it that's the way I would havei l

10 took it if a man told me that.

'l Q

But he didn't tell you that.

i 12 A

No, he told that.

That's the way I 13 definitely took it.

Id Q

Now Mr. Howard, you say you left the room 15 after this second conversation, i

16 A

Yes, I just let it cool off, you know, a 17 little bit.

And I just got up and left.

1B Q

Now Mr. Howard, did you discuss this matter 10 with after it occurred that day?

20 A

Wasn't none of my business.

,s

-/

21 Q

Have you ever discussed it with

-J 22 since that day?

l 23 A

Well, I'm sure that we talked about it on l

2d the job, but as far as discussing it since, no, I haven't i

25 discussed it with him.

I

17 f

]

P' l

1 Q

Did ec11 you up since you left the 2

job?

j 3

A I've talked to him over the phone, year sir.

4 Q

Did he ask you if you recalled thist 5

A Se Gsked me if I recalled the incidsnt and i

l 1

e i said, yaah, 1 said, I remember.it.

7 Q

How many times did he call you about this B

incident?

9 A

Once about this i r.c i d e n t.

10 Q

More than once about ocher things.

1 11 A

Well, yes when he was coming up he. pod'know, 12 wanted to visit, this and that.

1 j

13 Q

Did show you any notes that he 14 mzde about this conversation at any time?

15 A

No.

i 16 Q

Never has.

17 A

No.

18 MS. GARDE:

You're well beyond five questions.

10 MR. DOWNEY:

I've never been able to count 20 so well.

1 21 THE WITNESS:

I! o, let him shoot.

If he thinks 22 l'm lying to him, let him shoot.

I'm not lying to him.

23 MS. CARDE:

I think Mr. Downey realizes that.

end 2.

24 THE WITNESS:

I have no reason to lie.

25

1 l

l 18 1

1 mn31b1

{

i BY MR. D0hiEY:

1 2

Q Did you ever see this fellow from TUCCO j

again,. who came in that morning?

4 A

I'm sure I'vc seen him, but I couldn't recall 5

any definite place.or time. '; hough.

6 Q

Mad you seen him before'that morning?'

]

)

A Oh, yes.

8 Q

Someona that.wo7ks at the site?

'f i

9 A

Yes, s'r.

.10 Q

After this conversation, were you upset?

ti A

Was I upset?

Not really, cause 1t bothers

{

l 12 a person whn has been working for an engineer, it bothers 1

13 thes S little' bit because you've got people coming-doun 14 that should le trying er find oct dig a little' deeper f

1 is into this, rather than people that just doesn't seem to s[]

16 really care and just wanting to --

l 17 Q

Do you know how deeply this unnamed.fel)ow

{

18 had dug into this problem, b1 fora that morning?

l 1

A No. I don't know how deep.he had, but I 20 don't feel -- well.I don't know.

21 Q

Did ycu make any effort-to find out his namel i

22 A

Did I?

'1 23 Q

Yes.

24 A

Why should I?

25 Q

Do you knov if this matter, concerning the l

l

i 19 mn31b2 1

I cable separation, was ever resolved?

2 A

No, I was changed about two days later.

I 3

was sent to another engineer.

4 Q

What company did you work for while you S

were at the site?

6 A

Brown & Root.

7 Q

Mr. Howard, I just want to go back te one l

r.-

8 point.

You t e s r:i f ie d, in your direct examination, that f,

~,

9 ih & 6 telephoned New York. Do you recall that

. )

10 testimony?

11 A

Yes.

12 Q

Are you sure it was New York that he called?

13 A

I'm not oositive.

I think it was New York, I

l 14 to the'best of my --

15 Q

What makes you think it was New York?

10 A

That's Gibbs & Hill main offic,e and I feel 17 like thas where he called.

1B Q

You t h iith h e called Gibbs & Hi!1, but you 14 aren't certain?

20 A

Oh, I cculdn't say yes, that's definitely 21 where he called.

But I'm -- I fec1 like it's -- I'm just 22 going on memory.

j 23 Q

That's all we can go on.

24 MR. DOWNEY:

I have no more questions.

25 MR. MIZUNO)

Off the record.

L

x 20 S3 1

(Discuscion off the record.)

f 2

MR. M12UNO:

While we were off the record, 3

we had a short discussion'between counsel involvfog Mr, i

4 3 Hcsard's avaliabilimy to come back for further cross-

'l 5

examination.

Counsel for Interveners, Billie' Garde, 6

indicated that Mr. Howard would not be available in the-7

.f t1 t u r e.

And Mr. Downey indicated that'he was rePerving 8

his right to cross-examination.

g a

Staff is beginning its discovery at this to point and is also reserving its right for cross-examination I

11 in the future.

l

'2 EXAMINATION i

13 BY MR. III2UNU:

J 14 Q

Mr. Howard, are you en engineer?

.. y 15 A

No.

16 Q

Just an electrician?

17 A

Right.

18 Q

Who is your immediate supervisor?

't to A

Ben Baxter.

20 Q

Are you considered a construction person?

21 A

Well, ;. was when I was out there, yes.

22 j Q

Are you in the startup group?

23 A

Yes.

24 Q

You indicated that you believe that 25 alled New York and you believe that was the case

\\

4 i

k I

9

21 a r>31 bA

'l I

i because Cibbs & Hill was in New York, How did you knov

<~

2 that called Gibbs 6 Hill?

4 3

A TLey were the ones that designed this g

d nuclear plant and that's where he would have to go to get l

5 the correct answers.

That's where I would go if I were i

j 6

in his shoes.

7 i

MS. GARDE:

Mr. Mizuno, I think you're

)

8 mischaracterizing his enacimony.

9 BY NR. MIZUN04

~

.,g to Q

So did\\

'tell you that he was Il go;ng to call Gibbs & Hill?

12 A

l'm not sure.

I don't remember.

I don't 13 remembe2 everything that went on that day.

14 i

MR. MiZUNO:

I guess that's about it.

f 15 MS. GARDB:

I have two other questions.

16 EXAMINATION II BY MS. CARDE:

18 Q

You were asked questions by Mr. Downey regarding the procedures and the documents that(

20 had in his possession.

I believe your response was that 21 you thought it was a test for turnover documents. Are 22 those the kind of documer.cs that you usually work with.

-s 23 with i

24 V

A Yes, this was probably an SWA.

25 Q

But you're not sure?

4

22

...31b5 1

A Well, I'm about 90 percent sure this was 2

a Start Work Authorization.

3 Q

But you did not see the documents?

d A

Well, I seen them.

I had seen hem over 5

the new transition.

6 Q

The documents you were working on?

i l

7 A

Yes.

8 Q

Mr. Howard, I also ask you if you remember 9

if had raised questions rbout these procedures 10 onsite, to his supervisors.

And vour response was thet you 11 think that he did, because he was raising questions, or 12 wasn't satisfied with some of the procedures.

You were 33 not in a position to comment on the adequacy of procedures, Id were you?

15 A

No.

30 Q

So you weren't in a position to second guess 17 or the man f rom TUCCO 's concerns about whether 18 the procedures were adequate or not?

I' A

No, I was just surprised that the plant would 20 come in there using that type of a voice and authority 21 that was not necessary.

22 Q

Mr. Howard, you agreed to testify at the 23 request of CASE, in support of this incident, didn't you?

24 g

yes, 25 Q

And the sole purpose of your testimony was

9 23 r.;31b6 1

to give your firsthand knowledge about this incident 2

that we've talked about this morning?

3 A

Yes.

4 Q

You're not here to make any complaints against 5

Brown & Root, are you?

6 A

No.

7 Q

You're not 11e re to indicate that you were 8

harassed or intimidated in any way?

9 A

No.

to

  • t15. GARDE:

No fierther questions.

11 MR. DOWNEY: Thank you, Mr. How a r d.,

Sorry we 12 Lept ycu sc-long.

13 (Whereupon, at 8:00 a.m.,

the taking of the 14 deposition was concluded.)

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Larry D.

Howard j

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(

22 23 24 25

)

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6 CERTIFICATE. OF' PROCEED!.';G3 a

Chis is to certify that the attached proceedings before the 3

J'RC Cote 1ISSION 5

In the matter of:

Texas Utilities Electric Company. et al Deposition of Larry D.

Howard (In Camera)

Date of Proceedina:

Friday, July 20, 1984 Place of Proceeding:

Glen Rose. Texas were held as herein appears, and that this ir the original transe:-ipt for the file of t.he Commission.

to 15

.Marilynn Nations Official Reporter - Typed 12

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m&2 s, 'i, y, n n fl '~r lft m L'

~Of ficiad ' Reporter - Signature 15 16 17 18 4

19 f

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20 1

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TAYLCE ASSOCIATE 5 REGISTERED PROFESSIONAL REPORTCNS NCRFOLK, VIRGIN!A s

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