ML19329D312
| ML19329D312 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 01/13/1976 |
| From: | Reynolds W CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TOLEDO EDISON CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19329D309 | List: |
| References | |
| NUDOCS 8002270902 | |
| Download: ML19329D312 (3) | |
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Janu9ry 13, 1976 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
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THE TOLEDO EDISON COMPANY and
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THE-CLEVELAND ELECTRIC ILLUMINATING
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Docket No. 50-346A
. COMPANY
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(Davis-Besse Nuclear Power Station,
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Unit 1)
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THE CLEVELAND ELECTRIC ILLUMINATING
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Docket Nos. 50-440A (Perry Nuclear Power Plant,
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50-441A Units 1 and 2)
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THE TOLEDO EDISON COMPANY, ET AL,
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(Davis-Besse Nuclear Power Station,
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Docket Nos. 50-500A Units 2 and 3)
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50-501A APPLICATION FOR ISSUANCE OF SUBPOENAS 1.
Pursuant to Section 2.720(a) of the Commission's Rules of Practice, 10 C.F.R. 52.720(a), Applicants hereby request the Licensing Board to issue the attached four sub-poenas to:
a.
American Municipal Power-Ohio, Inc.
20 High Street Hamilton, Ohio 45013 b.
Mr. John C.
Engle American Municipal Power-Ohio, Inc.
20 High Street Hamilton, Ohio 45013 c.
Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 d.
Mr. George T. Berry Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 8002270 [O 2
r
. 2.
The subpoenas request the production of certain documents specifically referred to in the testi-mony of Warren D. Hinchee during the evidentiary hearing in the above-captioned proceeding on January 5 and 6, 1976.
Mr. Hinchee testified that there exist letters evidencing written requests for nuclear power by AMP-Ohio to Appli-cants and written responses by Applicants to those requests.
He also testified that there was a letter of intent exe-cuted between PASNY and AMP-Ohio committing PASNY power to AMP-Ohio.
3.
Applicants have re-examined the discovery materials produced by the other parties and by AMP-Ohio in an effort to locate the referenced documents; we have not found any of them.
The purpose of these subpoenas is to secure these specific documents in the most expeditious and least burdensome manner possible.
Applicants believe that the AMP-Ohio correspondence referred to by Mr. Hinchee should be produced, if it indeed exists, so that the Licens-ing Board will be in a position to base its decision on the most complete and accurate record that can be made.
WHEREFORE, Applicants request this Board to issue the attached subpoenas and deliver the executed subpoenas
c
, to the undersigned counsel for Applicants for purposes of implementing service of process.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 3
.2 S k. 's 5..,..E.
By:...
Wm. Bradford Reynolds \\
Counsel for Applicants Attachments Dated:
January 13, 1976.
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