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Application for Issuance of Subpoenas Calling for Deposition of Jr Milford,S Phelps,P Meyers,Hj Marsh,Ra Yarbrough, Gr Harrison,R Segrest,D Wright,Fj Meyer,A Higginbotham & Jm Ammons.W/Twelve Drafts of Subpoenas & Certificate of Svc
	ML19256G268
Person / Time
Site:	South Texas
Issue date:	12/14/1979
From:	Franklin W; BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	;
References
	NUDOCS 7912280630
	Download: ML19256G268 (90)
	v • d • e

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\

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S APPLICATION FOR ISSUANCE OF SUBPOENAS Houston Lighting and Power Company, pursuant to 10 C.F.R.

SS2.740, and 2.741, applies for the issuance of the attached Sub-poenas, which call for a, deposition requiring the attendance of v

the party listed, and fok production of documents. The testimony 1

anddocumentproductionsokhtencompasses,butisnot limited to, the testimony to be given in the instant proceeding, interest in and awareness of nuclear power projects, interconnections and operations involving interstate systems and the Texas Inter-connected Systems, bulk. electric power supply, transmission planning, and fuel supply for electrical generation of electricity.

Subpoenas (1) John R. Milford, City of Seymour 1650 121 (2) Sam Phelps, City of Vernon (3) Paul Meyers 79122 % b m

.. s.

(4) Harold J. Marsh, Electra Hospital (5) R.A. Yarbrough (6) Gene R. H a s. r i s o n , City of Hondo (7) Ross Segrest (8) Douglas Wright (9) Frank J. Meyer, Public Service Co. of Oklahoma (10) Alton Higginbotham, Lighthouse Electric Cooperative, Inc.

(11) Keeper of Records, Tri-County Electric Cooperative (12) John M. Ammons, Tri-County Electric Cooperative Respectfully submitted, Dated: December 14, 1979 J1 L c

/ Aw Attorney for Houston Lighting

& Power Company Baker & Botts 3000 One Shell Plaza Houston, Texas 77002 Lowenstein, Newman, Reis, Axelrad

& Toll 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 1650 122

UNITED STATES OF AMERICA NUCLEAR REGULATORY COM"ISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: John M. Ammons Tri-County Electric Cooperative 600 N.W. Parkway Azle, Texas 76020 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, Hilton Inn to appear at the 1701 Coamarge. Street,. . . in the City of F,t., Worth, Texas,

, . . on the 1st . . day of F,ebruary, 1,9 8,0 ,

at9:.30 A.M. (and thereaf ter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached scheduJe.

1650 123

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2.720(f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

~

i650 124

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Ccmpany and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas -Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or convercations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the t_sirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forda may adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 125

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Tri-County Electric Cooperative since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the Tri-County Electric Cooperative in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between Tri-County Electric Cooperative and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between Tri-C;unty Electric Cooperative and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 126

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 127

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

t 1650 128

f RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . . .

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 129

.4_,.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: Keeper of Records Tri-County Electric Cooperative 600 N. W. Parkway Azle, Texas 76020 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act, as amended, and 10 C.F.R. 52.720, to make available Hilton Inn, for inspection and copying at the l.702 .Commer.ce, S,tr,ee,t,. . in the City o f F,t ., Wor,th, ,Te;<a,s ,.

, . on the 31,st. day of J,anua,ry,,

19.80 atL: 3,0 p .M., the document (s) or object (s) described in the attached schedule, and to appear at such time to testify by deposition on oral examination in the above-entitled action as to the records of the Tri-County Electric Cooperative, and the manner of production of documents under this Subpoena.

1650 130

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2.720(f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

\65D \h\

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to cr received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any.other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting fords anyadverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council, 1650 132

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Tri-County Electric Cooperative since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the Tri-County Electric Cooperative in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between Tri-County Electric Cooperative and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between Tri-County Electric Cooperative and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

I650 133

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced on reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 134

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

1650 135

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . . .

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $ .

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 136

ny UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO:

Alton Higginbotham Lighthouse Electric Cooperative, Inc.

201 West California Street P. O. Box 580 Floydada, Texas 79235 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954 as amended, and 10 C.F.R. S2.720, Besb Western South Park Inn to appear at the3201 Logp,289,Sguth. . . . . in the City of Lubbgch,, Texas t . . on the . . 30th. day of January, 1980, at9;30 A.M.(and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 137

.s V BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2.720 (f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

1650 138

y SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instan:es of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulato.'..y Commission.

3. Ali documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brounsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

i650 139

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Lighthouse Electric Cooperative, Inc. since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the Lighthouse Electric Cooperative, Inc. in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between Lighthouse Electric Cooperative, Inc. and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between Lighthouse Electric Cooperative, Inc. and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 140

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify t'.e specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoer a which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, ple3se provide the following:

(a) date; (b) type of document; (c) identity of author and addresses;

( 7) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis fcr the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however prcdaced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, raeeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyser, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 141

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

e 1650 142

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . ..

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . ..

Service Fees Travel. . . . . . . . . . . . . S Services. . . . . . . . . . . . $

Total. . . . . . . . . . . . .. S Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 143

_e

)?

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the /iatter of S S

HOUSTON LIGHTING & POWER COMPANY & Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: Frank J. Meyer Public Service Co. of Oklahoma Box 201 Tulsa, Oklahoma 74102 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, to appear at .

the Hilton Inn, 5000 East Skelly Drive, in the City of Tulsa, Oklahoma, on the 22nd day of January, 1980, at 9:30 A.M.,

(and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-mentioned action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 144

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 7 20 ( f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the ,

presiding officer or, if he is unavailable, the ammission 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.

1650 145

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conver-sations with any attorney for or employee of the U.S. Depart-ment of Justice or U.S. Nuclear Regulatory Commission. Exclude documents which relate to the environmental or health and safety hearings for Black Fox Station.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Coopera-tive, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C.H. Guernsey Corporation; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Council.

6. All docmments referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Public Service Company of Oklahoma.

1650 146

8. All documents referring or relating to or setting forth each transmission study developed by or for the Public Service Company of Oklahoma in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth each generation and/or transmission plan for, or in connection with, the electrical integration of the Central and Southwest Corporation operating companies.

10. All documents referring or relating to or setting forth any effects upon any non-central & Southwest Corporation operating company resulting from or in connection with any of the generation and/or transmission plans covered.in item 9 above.

i650 147

= 4 Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its m(aning, all or original (or copies where originals are unavailable) and non-identical copies (whether dif ferent from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses- notes, books, records, reports, summaries and results of' .avestigations and tests, reviews, contracts, agreement, pamphlets, diaries,. calendar 1650 148

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

0 0

1650 149

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . ...

. . . . . . . . . . served it on the within named. . ..

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . ...

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $ .

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 150

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & PONER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO:

Douglas Wright 1759 South Quincy Tulsa, Oklahoma 74120 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, Hilton Inn, 5000 East Skelly Drive, to appear at the . . . . . . . . . . . . . . in tne City Tulsa, Oklahoma, 21st January, 1980, of . . . . . . . . . . on the . . . . . day at . . . . . ..

at . 9 : 3 0 A. M(.and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 151

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 720 (f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

1650 152

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas 31ectric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Departmer.t of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 153

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Southwestern Power Administration since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the Southwestern Power Administration in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between Southwestern Power Administration and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between Southwestern Power Administration and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 154

l .-

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies

- or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type af conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar

)650 155

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or ravisions of any of the foregoing and any supporting, underlying or preparatory material.

e 1650 156

~ . .*

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . . .

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $ .

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 157

.. n - f .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO:

Ross Segrest 1521 Lake Air Drive Suite 118 Waco, Texas 76710 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. 52.720, Best Western Old Main Lodge to appear at the Integstate , Highway ,3Q, . . . in the City of .Waco, ,Tgxas . . . . on the . . , 16tD . day ofJangagy, 1980, at }- }0 P.MTand thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimeny will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 158

g ..

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2.720 (f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to -

the party at whose instance the subpoena was issued, the presiding officer 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.

1650 159

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light' Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Coramis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any o*.her form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 160

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Brazos Electric Power Cooperative, Inc. since January 1, 1973.

8. All documents referring or relating to or setting fo_th each transmission study developed by or for the Brazos Electric Power Cooperative, Inc. in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between Brazos Electric Power Cooperative, Inc. and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between Brazos Electric

?ower Cooperative, Inc. and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 161

b Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of.the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summar.ies and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar i650 162

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denc=inated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

1650 163

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . ......

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $

Total. . . . . . . . . . , . .. $

Subscribed and sworn to before me, a . . . . . . ..

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 164

y . .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Dockst Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S .

(South Texas Project, Units Nos. S k-1 and 2) S SUBPOENA TO: Gene R. Harrison City Manager City of Hondo 1600 Avenue M Hondo, Texas 78861 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, Hilton Palacio del Rio, 200 S. Alamo Street, to appear at the . . . . . . . . . . . . . . In the City San Antonio, Texas, 15th January, 1980, of . . . . . . . . . . on the . . . . . day of . . .....

at 9:30 A.M(and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 165

9 i BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 7 20 ( f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

i650 166

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relatit 3 to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documuats referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 167

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for City of Hondo since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the City of Hondo in connection with any of the bulk power suppli plans covered in item number 7 above.

9. All documents referring or relating to or settire forth correspondence or contracts between City of Hondo and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between City of Hondo and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 168

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded-or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or s9urd recordings of any type of conversation, meeting o' son ference, minutes of directors' or committee meetings, ue iraQda, inter-office communications, studies, analyses n;,0- books, records, reports, summaries and results of i.. gations and tests, reviews, contracts, agreement, paroblets, diaries, calendar 1650 169

9 .

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

1650 170

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . . .

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

i650 171

g . i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO:

R. A. Yarbrough 1311 Avenue J., N.W.

Childress, Texas 79201 (Mailing Address)

P. O. Box 764 Childress, Texas 79201 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954,"as amended, and 10 C.F.R. S2.720, Holiday Inn, 8th & Scott Streets to appear at the . . . . . . . . . . . . . . In the City ofWichita Falls, Texas,on the . . . . llth. day of January, 1980, at g.}0 A.Miand thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

i650 172

4 BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2.720(f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

1650 173

s SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subridiaries including without limitation Central Power and Ligh. Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 174

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for Gate City Electric Cooperative since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the Gate City Electric Cooperative in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between Gate City Electric Cooperative and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between Gate City Electric Cooperative and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 175

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document;

( f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 176

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

9 9

1650 177

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . ....

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . ....

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $ .

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 178

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO:

Harold J. Marsh Electra Hospital South Highway 25 Electra, Texas 76360 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, to appear at thdioliday Inn, 8th & Scott Streets,the

* - - - - - . . . . . . . In City of Wic,hita Falls, Texas, on the 10th

. day of January, 1980, at 9.: 3,0 ,A.M.(and thereaf ter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

\650 \19

BY ORDER OF THE ATOi1IC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 '

10 C.F.R. 2.720 ( f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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 ssue, or (2) condition denial of the motion on just and reasonable terms.

1650 180

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in t he Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 181

L

7. All documer referring or relating to or setting forth correspondence or contracts concerning the availability of, alternatives for, or the purchase of wholesale or bulk electric power from any electric utility or electric cooperative.

1650 182

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 183

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

1650 184

RETURU ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . ..

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . ..

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 183

I h* UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: Mr. Paul Meyers Attorney At Law 109 North Main Street Electra, Texas 76360 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, Holiday Inn, 8th & Scott Streets to appear at the . . . . . . . . . . . . . . In the City of W.ichita Falls, Texas on the . . . . . 9th day of January, 1980, at 9: 30 A.M.(and thereaf ter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 186

i W BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 720 (f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

1650 !87

SCHEDULE TO SUBPOENA i et -

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power. Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting fordi any adverse ef fects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 188

7. All documents referring or relating to or setting forth correspondence or contracts concerning the availability of, alternatives for, or the purchase of wholesale or bulk electric power from any electric utility or electric cooperative.

1650 189

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, pleasc provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 190

,or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

9 0

1650 191

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . ......

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $ .

Total. . . . . . . . . . . . .. S Subscribed and sworn to before me, a . . . . . . ..

this. . . . . day of. . . . . . . . . . ., 19. ..

1650 192

g_ 9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: Sam Phelps City Manager City of Vernon Box 1423 Vernon, Texas 76384 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S2.720, Holiday Inn, 8th & Scott Streets to appear at the . . . . . . . . . . . . . . In the City Wichita Falls, Texas 8th January, 1980, of . . . . . . . . . . on the . . . . . day of . . . . . . .

at 9:30,A.M(and thereafter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

\650 \93

y BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD By

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 7 20 ( f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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.

1650 19^

4 SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of cumpetition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of che City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 195

7. All documents raferring or relating to or setting forth each bulk power supply plan prepared by or for the City of Vernon since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the City of Vernon in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between City of Vernon and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between City of Vernon and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

.1650 196

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or FC as Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (wnether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existcace, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlens, diaries, calendar i650 197

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

1650 198

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . . . .

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . . . .

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $

Total. . . . . . . . . . . . .. $

oubscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 199

. i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket Nos. 50-498A THE CITY OF SAN ANTONIO S 50-499A THE CITY OF AUSTIN and S CENTRAL POWER AND LIGHT COMPANY S S

(South Texas Project, Units Nos. S 1 and 2) S SUBPOENA TO: John R. Milford City Administrator City of Seymour P. O. Box 31 Seymour, Texas 76380 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. 52.720, to appear at the Holiday Inn, ,8th,&, Scott,Sgsin the City of Wichita Falls, Texas on the

, . 7th. . day of January,,1980 at 9 : 30, A.M(and tl:ereaf ter from day to day, if necessary) to testify by deposition on oral examination in the above-entitled action, and to bring with you the document (s) or object (s) described in the attached schedule. Your testimony will be required as to the testimony you may give in the trial of this action, all matters relating thereto, and all subject matters covered in the attached schedule.

1650 200

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD B y__

. . . . . . ., 19. .

J. Gregory Copeland Attorney for Houston Lighting

& Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713)229-1234 10 C.F.R. 2. 7 20 ( f)

On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer 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 june and reasonable terms.

1650 201

SCHEDULE TO SUBPOENA

1. All documents referring or relating to or setting forth instances of competition with (1) Houston Lighting &

Power Company and/or (2) Texas Power & Light Company and/or (3) Texas Electric Service Company, and/or (4) Dallas Power

& Light Company; and any communications with any of the aforementioned entities.

2. All documents provided to or received from the U.S.

Department of Justice or the U.S. Nuclear Regulatory Commis-sion in connection with this action or the licensing of any nuclear powered electric generation plant. All documents referring or relating to or setting forth meetings or conversations with any attorney for or employee of the U.S.

Department of Justice or U.S. Nuclear Regulatory Commission.

3. All documents provided to or received from an attorney for or an employee of: (1) the Public Utilities Board of the City of Brownsville, Texas; (2) Tex-La Electric Cooperative, Inc.; (3) the Committee on Power for the Southwest; (4) Tex-La of Texas, Inc.; (5) C. H. Guernsey Corporation; (6) Central and Southwest Corporation and/or any of its subsidiaries including without limitation Central Power and Light Company, West Texas Utilities Company, Public Service Company of Oklahoma and Southwestern Electric Power Company; and any documents referring or relating to or setting forth meetings or conversations with any of the aforementioned entities.

4. All documents referring or relating to or setting forth consideration given to ownership, or any other form of participation, in any nuclear power electric generating plant.

5. All documents referring or relating to or setting forth the desirability or feasibility of interconnecting the electric systems in the Texas Interconnected Systems and the Electric Reliability Council of Texas and (1) the Southwest Power Pool, and/or (2) Western Systems Coordinating Councul.

6. All documents referring or relating to or setting forth any adverse effects resulting from the present lack of interconnections between the Texas Interconnected Systems and/or the Electric Reliability Council of Texas with (1) the Southwest Power Pool and/or (2) the Western Systems Coordinating Council.

1650 202

7. All documents referring or relating to or setting forth each bulk power supply plan prepared by or for City of Seymour since January 1, 1973.

8. All documents referring or relating to or setting forth each transmission study developed by or for the City of Seymour in connection with any of the bulk power supply plans covered in item number 7 above.

9. All documents referring or relating to or setting forth correspondence or contracts between City of Seymour and any electric utility or electric cooperative concerning the purchase and/or sale of electric power.

10. All documents referring or relating to or setting forth any correspondence or contracts between City of Seymour and any electric utility or electric cooperative concerning the purchase and/or sale of fuel to be used for the generating of electric power.

1650 203

Instructions The period of time for which documents are requested in-cludes the entire period from January 1, 1970 to the date on which documents are made available for inspection and copying by Houston Lighting & Power Company or Texas Utilities Generating Company or their representatives.

Houston Lighting & Power Company and Texas Utilities Generating Company request that the Keeper of the Records identify the specific request or requests to which each document is responsive. Where possible, the Keeper of the Records is requested to maintain the integrity of its filing and recordkeeping systems by producing together documents responsive to this subpoena which are found together in the Keeper of the Records' files.

If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) i.dentity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or conference, minutes of directors ' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreement, pamphlets, diaries, calendar 1650 204

or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, '

however denominated, incluidng preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

1650 205

RETURN ON SERVICE Received this subpoena at . . . . . . . . . . . . . . . .on

. . . . . . . . . . .and on. . . . . . . . . . at. . . ...

. . . . . . . . . . served it on the within named. . . .

. . . . . . . . . . . by delivering a copy to h. . . and tendering to h. . . the fee for one day's attendance and the mileage allowed by law.

Dated . . . . . . . . . 19. . . By . . . . . . . . ...

Service Fees Travel. . . . . . . . . . . . . $

Services. . . . . . . . . . . . $ .

Total. . . . . . . . . . . . .. $

Subscribed and sworn to before me, a . . . . . . . .

this. . . . . day of. . . . . . . . . . ., 19. . .

1650 206

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

)

HOUSTON LIGHTING & POWER ) Docket Nos. 50-498A COMPANY, et al. ) 50-499A

)

(South Texas Project, )

Units 1 and 2) )

)

TEXAS UTILITIES GENERATING ) Docket Nos. 50-445A COMPANY, et al. ) 50-446A

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the foregoing APPLICATION FOR ISSUANCE OF SUBPOENAS and Twelve Attached Subpoenas, dated December 14, 1979, were served upon the following persons, by hand *, or by deposit in the United States Mail, first class postage prepaid, this 14th day of December, 1979.

A

/

1650 207

. e

Marshall E. Miller, Esquire Frederic D. Chanania, Esquire U.S. Nuclear Regulatory Commission Roy P. Lessy, Jr., Esquire Washington, D.C. 20555 Michael B. Blume, Esquire Ann P. Hodgdon, Esquire

Michael L. Glaser, Esquire U.S. Nuclear Regulatory Commission 1150 17th Street, N.W. Washington, D.C. 20555 Washington, D.C. 20555 Roff Hardy

Sheldon J. Wolfe, Esquire Chairman and Chief Executive U.S. Nuclear Regulatory Commission Officer Washington, D.C. 20555 Central Power and Light Company Post Office Box 2121 Atomic Safety and Licensing Corpus Christi, Texas 78403 Appeal Board Panel U.S. Nuclear Regulatory Commission G.K. Spruce, General Manager Washington, D.C. 20555 City Public Service Board Post Office Box 1771

Chase R. Stephens, Supervisor (20) San Antonio, Texas 78203 Docketing and Service Branch U.S. Nuclear Regulatory Commission Mr. Perry G. Brittain Washington, D.C. 20555 President Texas Utilities Generating Company Mr. Jerome D. Saltzman 2001 Bryan Tower Chief, Antitrust and Indemnity Dallas, Texas 75201 Group U.S. Nuclear Regulatory Commission G.W. Oprea, Jr.

Washington, D.C. 20555 Executive Vice President Houston Lighting & Power Company J. Irion Worsham, Esquire Post Office Box 1700 Merlyn D. Sampels, Esquire Houston, Texas 77001 Spencer C. Relyea, Esquire Worsham, Forsyth & Sampels R.L. Hancock, Director 2001 Bryan Tower, Suite 2500 City of Austin Electric Utility Dallas, Texas 75201 post Office Box 1086 Austin, Texas 78767 Jon C. Wood, Esquire Matthews, Nowlin, Macfarlane Joseoh Gallo, Esquire

& Barrett Robert H. Loeffler, Esquire 1500 Alamo National Building Isham, Lincoln & Beale San Antonio, Texas 78205 1050 17th Street, N.W., Suite 701 Washington, D.C. 20036 Charles G. Thrash, Jr., Esquire E.W. Barnett, Esquire Michael I. Miller, Esquire Theodore F. Weiss, Esquire James A. Carney, Esquire J. Gregory Copeland, Esquire Sarah Welling, Esquire Baker & Botts Isham, Lincoln & Beale 3000 One Shell Plaza One First National Plaza Houston, Texas 77002 Suite 4200 Chicago, Illinois 60603 R. Gordon Gooch, Esquire Steven R. hunsicker, Esquire David M. Stahl, Esquire Baker & Botts Isham, Lincoln & Beale 1701 Pennsylvania Avenue 1050 17th Street, N.W.

Washington, D.C. 20006 Suite 701 Washington, D.C. 20036 1650 20B

'

Don R. Butler, Esquire David A. Dopsovic, Esquire Sneed, Vine, Wilkerson, Selman Frederick H. Parmeter, Esquire

& Perrr Susan B. Cyphert, Esquire Post Office Box 1409 Nancy A. Luque, Esquire Austin, Texas 78768 Energy Section Antitrust Division U.S. Department of Justice Mr. William C. Price P.O. Box 14141 Central Power & Light Company Washington, D.C. 20044 P.O. Box 2121 Corpus Christi, Texas 78403 Morgan Hunter, Esquire Bill D. St. Clair, Esquire Mr. G. Hol' man King McGinnis, Lockridge & Kilgore West Texas Utilities Company Fifth Floor P.O. Box 841 Texas State Bank Building Abilene, Texas 79604 900 Congress Avenue Austin, Texas 78701 Jerry L. Harris, Esquire Richard C. Balough, Esquire W.S. Robson City of Austin General Manager P.O. Box 1088 South Texas Electric Cooperative, Inc.

Austin, Texas 78767 Route 6, Building 102 Victoria Regional Airport

.70seph B. Knotts, Jr., Esquire Victoria, Texas 77901 Nicholcs S. Reynolds, Esquire Debevoise & Liberman Robert C. McDiarmid, Esquire 1200 17th Street, N.W. Robert A. Jablon, Esquire Washington, D.C. 20036 Marc R. Poirier, Esquire Spiegel & McDiarmid Don H. Davidson 2600 Virginia Avenue, N.W.

City Manager Washington, D.C. 20037 City of Austin .

P.O. Box 1088 Kevin B. Pratt Austin, Texas 78767 Texas Attorney General's Office P.O. Box 12548 Jay Galt, Esquire Austin, Texas 78711 Looney, Nichcis, Johnson & Hays 219 Couch Dr;.ve William H. Burchette, Esquire Oklahoma City, Oklahoma 73102 Frederick H. Ritts, Esquire Law Offices of Northcutt Ely Knoland J. Plucknett Watergate 600 Building Executive Director Washington, D.C. 20036 Committee on Power for the South-west, Inc. Tom W. Gregg, Esquire 5541 East Skelly Drive P.O. Box Drawer 1032 Tulsa, Oklahoma 74135 San Angelo, Texas 76902 John W. Dairidson, Esquire Leland F. Leatherman, Esquire Sawtell, Coode, Davidson & Tioili McMath, Leatherman & Woods, P.A.

1100 San Antonio Savincg Euilding 711 West Third Street San Antonio, Texas 78205 Little Rock, Arkansas 72201 Douglas F. John, Esquire Paul W. Eaton, Jr., Esquire Akin, Gump, Hauer & Feld Hinkle, Cox, Eaton, Coffield & Hensley 1333 New Hampshire Avenue, N.W. 600 Henkle Building Suite 400 P.O. Box 10 Washington, D.C. 20036 Roswell, New Mexico 88201 1650 209

Robert M. Rader, Esquire Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006 W.N. Woolsey, Esquire Dyer and Redford 1030 Petroleum Corpus Christi, Texas 78474 Donald M. Clements, Esquire Gulf States Utilities Company P.O. Box 2951 Beaumont, Texas 77704 Dick Terrell Brown, Esquire 800 Milam Building San Antonio, Texas 78205 1650 210

ML19256G268: Difference between revisions

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ML19256G268: Difference between revisions

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