ML19344B364
| ML19344B364 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/19/1980 |
| From: | Pell D ANTI-NUCLEAR GROUP REPRESENTING YORK |
| To: | |
| References | |
| ISSUANCES-SP, NUDOCS 8008260793 | |
| Download: ML19344B364 (2) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9
In the Matter of METROPOLITAN-EDISON COMPANY, DOCKET No. 50-289 (Restart)
(Three-Mile Island Nuclear Generating Station, q'
Unit No. 1)
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4 NOTICE OF DEPOSITION TO:
Randy L. Curry, Director jj York County Emergency Management Agency i
FROM: Daniel M. Pell, Esquire Attorney for Anti-Nuclear Group Representing York j
DATE: August 19, 1980 l'
1 You are notified that you will be expected to appear to givai a deposition concerning the above matter on August 26, 1980, at 9 a.m. at the law office of Daniel M.
Pell, Esquire, located at l
32 South Beaver Street, York, Pennsylvania.
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You will be required to testify concerning your knowledge, if any, of the emergency planning and preparedness of York Countyi with reference to matters now pending before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission.
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Specifically, you will be asked to give testimony concerning, York County's emergency plan, its interrelationship with the planj of the Commonwealth of Pennsylvania and also what York County has!
i done with regard to coordination of its plan with local j
municipalities and townships.
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l You are required to bring with you a log of the test exercise in which York County participated in July, 1980.
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l failure to appear and/or to bring any requested documents may l
result in the issuance of a subpoena duces tecum to compel your j
attendance and the production of said documents.
Dan el M.
Pell
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Attorney for A.N.G.R.Y.
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- DANIEL M. PELL 7
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32 south BEAVER STR EET
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YORK. PENNSYLVANIA 174o1 E717) eds.easi 55 NORTH MAIN STR EET
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DOVER. PENNSYL\\ ANIA 17315 (717) 292 5303 August 19, 1980 Mr. Randy L. Curry, Director York County Emergency Management Agency York County Court House 28 East Market Street York, Pennsylvania 17401
Dear Mr. Curry:
Pursuant to our telephone conversation of this date, I hereby serve upon you a Notice of Deposition to appear in my law office on Tuesday, August 26, 1980, at 9 a.m. at 32 South Beaver Street, York, Pennsylvania.
As you will note in the Notice of Deposition, the purpose of this proceeding is to inquire into York County's emergency planning and preparedness.
You are requested to bring with you at this time a log of the July, ir 0 test exercise conducted by the Metropolitan-Edison Company, PEMA and York County in conjunction with the directive of the Nuclear Regulatory Commission.
t You indicated you feel you do not have to produce the log of the test exercise.
I indicated that I will give you this Notice of Deposition.
Should you fail to appear and/or fail to appear with the text of the log you kept in the exercise, I l
would apply to the Atomic Safety and Licensing Board Chairman, l
Ivan W. Smith, Esquire, for a subpoena duces tecum to compel l
you to attend and to produce the log of the test exercise.
If you do not intend to appear on August 26, 1980, please promptly notify me so that I may save much time and expense.
very truly yours, j
Daniel M. Fell DMP:ksw Enclosure pc:
Ms. Gail Bradford l
Legal Coordinator, A.N.G.R.Y.
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