ML20055E293
| ML20055E293 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, Rancho Seco  |
| Issue date: | 02/08/1990 |
| From: | Mackey S DONAHUE & CALLAHAM |
| To: | Jensen N NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20055C206 | List:
|
| References | |
| NUDOCS 9007110263 | |
| Download: ML20055E293 (2) | |
Text
-
i LAW OITICES j
sAmtst oowawve DONAltUE Ah CALLAIIAM cany u A>>stourt wiLuAu e callan. w wituAun mLanswont otaart w woop 0004 FAIN cAus DovLEVARD a'chAa0 t even.sa t
,",",",",,C,y,","= w oL ov en ITE 900 any wat s SACRAMENTO, CALIPOMNIA 95004 7904 gaviag gnicagou wALygn u. Loviwo su D"""""'"00'""^^*
mostata EAmo
.g,7y.JHONE Micuack& Mycas smanow w evantwgLL j
sgrrngy w LAustat (910) D72 1W12 siteng% s pacnty j
AtMLEEN M MH Ap%
j gg,, g g g,g SAmmv vosto February 6, 1990 6.
- .3 U. S. Nuclear Regulatory Commission Office of the General Counsel C"
Washington D.C. 20555 d
w Attention:
Mr. Neil Jensen p
C U. S. Nuclear Regulatory Commission, Region V
.r 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Attention:
Mr. Michael Blume Re:
Akins, et al. v. SMUD Gentlemen:
This letter and the enclosed Declaration is served in compliance with 10 CFR 9.200, et seq., seeking the approval of the General Counsel of the United States Nuclear Regulatory Commission to take the oral depositions of Chose NRC personnel identified as participants in the NRC investigation, Case No.
5-86-011.
We also seek to obtain copies of the docuitents acquired or generated by the NRC pertaining-to said investigation.
This investigation was conducted under the auspices of the NRC's Office of Investigation and the report identifies the participating HEC personnel as follows:
1.
Michael
- Cillis, NRC Region V,
Investigator Health Physicist 2.
Philip Joukoff, Office of Investigations, Region V,
Investigator of Investi ations, Region V, 3.
Ronald A.
Meeks, Office E
Investigator 4.
Owen C.
Shackleton, Jr.,
office of Investigations, Region V, Investigator 5.
Gregory Yuhas, Region V, Investigator.
6.
Robert Marsh, Director, Office of Investigations
-900711026390062fpf
&.hDR ADOCK Osooo FUC
g 1
Page 2.
February 8, 1990 U. S. Nuclear Regulatory Comeission Re:
Akins, et al. v. SMUD As the attached Declaration of Stephen J.
Mackey states, the oral deposition testimony of each of these individuals is sought on the ground that the evidence gathered and the opinions of these investigators are directly relevant to the major issues of the above-entitled litigation.
The anticipated areas of inquiry will involve the facts, the circumstances and the evidentiary materials generated by the above-identified NRC personnel during the NRC Office of Investigation's probe initiated on June 13, 1986.
We are s?ecifically requesting not only the deposition testimony of these individuals, but also the disclosure and production of all supporting documentation generated or acquired by these NRC personnel while working on the investigation.
more than The length of time away from duty should be no several days for each of these individuals.
Since this matter will go to trial on September 10, 1990, the time within which to conduct these depositions is limited and we would respectfully request prompt approval from the General Counsel so that all responsive documents can be produced immediately and these depositions taken as soon as possible.
Thank you for your courtesy and anticpted cooperation in expeditiously considering this demand for information.
If you have any questions, or need any further information, do not hesitate to contact me immediately.
Very truly yours, DONAHUE AND CALLAHAM STEPHEN J iACKEY SJM/m Enclosure
__.2m____________m_._._______