ML19249B909
| ML19249B909 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/07/1979 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Marsh R KROHN & HOEGEN |
| References | |
| NUDOCS 7909070069 | |
| Download: ML19249B909 (2) | |
Text
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o UNITED STATES 8k - y' n NUCLEAR REGULATORY COMMISSION E
WASHING TON, D. C. 20%5 s~s August 7,1979 D
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/w Robert E. Marsh, Jr., Esq.
6 Krohn and Hoegen, Attorneys-at-Law z/
"i MA 930 United Penn Bank Building f?
E Wilkes-Barre, Pennsylvania 18701
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In the Matter of J/
Pennsylvania Power and Liaht Co.
A/
Allegheny Electric Cooperative, Inc.
(Susquehanna Steam Electric Station, Units 1 and 2)
Docket Nos. 50-387 and 50-388
Dear Mr. Marsh:
Our letters dated July 16, 1979 must have passed in the mail.
In your letter dated July 16 you indicate that your client, Ms. Mary Kelchner Creasy, denies having made the statements attributed to her in the article, which appeared in the Berwick Enterprise-Bloomsburg Press of June 2-3, 1979 and a copy of which was attached to my letter of July 16. Moreover, you indicate that your client has advised you that the article as it relates to her is entirely false.
In my letter dated July 16 I had indicated that in view of the inconsistencies in the statements of Ms. Creasy as presented in your letter to me of July 3 and as attributed to her in the newspaper article, I believed the taking of her deposition to be imperative.
However, in light of your statement that Ms. Creasy completely repudiates the article as it relates to her, I am again willing to attempt to dispose of this matter via Ms. Creasy's affidavit.
If Ms. Creasy is able to execute an affidavit setting forth her unequivocal statement.(1) that her inability to provide more infomation to support allega-tions made by her at the January Prehearing Conference results from her lack of knowledge of additional facts rather than from any Secrecy Agrmments that she executed while employed by Bechtel Corporation and (2) that the article which appeared in the Berwick Enterprise-Bloonsburg Press of June 2-3 is completely false as it relates to her, the Staff believes that it can complete the report requested of it by the Licensing Board and dispose of this matter.
The form of the oath taken by Ms. Creasy should make clear that she makes the statenent freely and without mental reservation or purpose of evasion and that she swears that the statement is true.
I suggest that you call me to discuss the affidavit, after it is drafted but before it is executed, so that we can be sure that it will accomplish the 921233 7909070 C N
2-purpose intended--avoidance of the inconvenience and expense of an unnecessary deposi tion.
Sincerely,
~mp
~ :- MG..t James M. Cutchin, IV Counsel for liRC Staff cc: Charles Bechhoefer, Esq.
Mr. Glenn 0. 3right Dr. Oscar H. Paris Jay Silberg, Esq.
Dr. Judith H. Johnsrud Mr. Thomas M. Gerusky Ms. Colleen Marsh Mrs. Irene Le..:anowicz Susquehanna Environmental Advocates Atomic Safety and Licensing Appeal Board Panel Bryan A. Snapp, Esq.
Mr. Robert M. Gallo Atomic Safety and Licensing Board Panel Dv.keting and ervice Section 321234