ML19319C324
| ML19319C324 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 04/07/1975 |
| From: | Reynolds W CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TOLEDO EDISON CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19319C325 | List: |
| References | |
| TTPLED-750407, NUDOCS 8002130844 | |
| Download: ML19319C324 (4) | |
Text
April 7, 1975 ' y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board, In the Matter of
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THE TOLEDO EDIS0!! COMPANY and
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THE CLEVELAND ELECTRIC ILLUMINATING
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COMPANY
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(Davis-Desse Nuclear Power St.ation,
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Docket Nos. 50-346A Unit 1)
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50-440A
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50-441A THE CLEVELAND ELECTRIC ILLUMINATING
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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APPLICATION FOR ISSUANCE OF SUBPOENAS 1.
Pursuant to 10 C.F.R. Section 2.720a, Applicants hereby request thn Liennsing Poard to issue subpoenas to the following named individuals, requiring their attendance and testimony at oral depositions to be conducted at the offices of The Cleveland Electric Illuminating Company, 55 Public Square, Cleveland, Ohio, for purposes of discovery in the above-captioned matter, and requiring them to remain in attendance until released by the Board:
Name of Deponent Time and Date of to be subpoenaed Deposition William R. Mayben 9: 00 A.M.,
April 29, 1975 R. W. Beck & Associates 1453 - 29th Avenue Columbus, Nebraska 68601 Andrew Putka, Director 9: 00 A.M., May 6, 1975 Department of Port Control Cleveland Hopkins Airport
-Cleveland, Ohio 44114 8002 1go f i
- - =
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s Name of De onent Time and Date of to be subpoenaed Deposition George L. Forbes, Chairman 9: 00 A.M., May 8, 1975 Public Utilities Committee Council of the City of Cleveland Room 216, City Hall 601 Lakeside Avenue Cleveland, Ohio 44114 Arnold Turkel 9: 00 A.M., May 13, 1975 27050 Cedar Avenue Beechwood, Ohio 44122 2.
On December 6, 1974, Applicants made a similar application for subpoenas as to all of the aforesaid indi-viduals except City Council Member George L. Forbes, who~se name has been substituted in the present application for his earlier-named predecessor, Francis E. Gaul.
Pursuant thereto the then Chairman of this Licensing Board, John Firmakides, issued the requested subpoenas on December 11, 1974.
Following this action, however, the Board, by Order dated December 23, 1974, ruled that depositions by all parties were to be held in abeyance pending resolution of a separate j
issue relating to document discovery.
3 That issue has now been resolved and this Board has scheduled the deposition phase of prehearing discovery to commence on April 7, 1975 Applicants' present applica-tion for subpoenas is being submitted in accordance with that schedule.
Attached heretc are copies of the subpoenas.he issuance of which are requested.
4.
Applicants have good reason to believe that each of the foregoing individuals can testify to matters of par-ticular relevance to the claims made in the petition to intervene of the City of Cleveland.
William R. Mayben is a partner in R. W. Beck & Associates, the engineering consultants who prepared the engineerirg report on the Municipal Power & Light Plant ("MELP") included in the Pre-liminary Official Statement, dated May 10, 1974, for MELP's
$9,800,000.00 Bond Issue; it is believed that he can testify to matters. set forth therein relevant to the operations of the municipal plant.
Andrew Putka was formerly the Finance Director of the Division of Light and Power, responsible for MELP's financial affairs.
Arnold Turkel was formerly a Commissioner of Utilities Engineering, City of bleveland, and at the time had mar.agerial responsibility for engineering matters relating to MELP.
It is believed that Messrs. Putka and Turkel can testify to a number of matters referred to in the City of Cleveland's answers to Applicants' interroga-tories and in documents produced by the City.
George L. Forbes, as a member of the City Council, has direct 1:nowledge of the overall operations and financial position of MELP, and it is believed that he can testify to, among other things, MELP's financial capability t'o participate, by ownership or other-wise, in the designated nuclear plants.
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- 5 Pursuant to 10 C.F.R. Section 2.740a, Applicants, on April 7, 1975, caused to be served by mail on each of the above-named persons notices of deposition to be taken on the dates indicated herein; copies of said notices were served on the parties hereto and on the Chairman and mem-bers of the Licensing Board.
WHEREFORE, Applicants move this Board to issue the requested subpoenas and to deliver the executed sub-poenas to the undersigned counsel for Applicants, for ser-vice on the aforesaid witnesses.
Respectfully submitted, SHAW, PITTMAN, PCTTS & TROWBRIDGE By:
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___4 Wm. Bradforq Rsynoldy Gerald Charnoff Counsel for Applicants Enclosures Dated:
April 7, 1975
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