ML20097D225

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Application for Issuance of Subpoena Duces Tecum to C Faust Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence
ML20097D225
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/10/1984
From: Bernabei L, Doroshow J
GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20097D126 List:
References
SP, NUDOCS 8409170419
Download: ML20097D225 (4)
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Text

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'84 SEP 14 A9 33

TMIAt9(1 ce; w ,naa a d0 84 UNITED STATES OF AMERICA #

NUCLEAR REGULATORY COMMISSION -

Before the Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISION COMPANY ) Docket No. 50-289

) (Restart-Management (Three Mile Island Nuclear ) Dhase)

Station, Unit 1) )

APPLICATION FOR ISSUANCE OF SUBPOENA DUCES TECUM Pursuant to Section 2.720 of the Commission's regulations, Intervenor Three Mile Island Alert applies to the Atomic Safety 1

and Licensing Board for the issuance of a Subpoena Duces Tecum to Craig' Faust, employee of Licensee, for the purpose of requiring the above-named individual to produce documents at the deposition scheduled to commence in this matter on September 21, 1984 at 2:30 p.m. A copy of the proposed Subpoena is attached.

The documents of Mr. Faust are relevant to the issue of the "Dieckamp mailgram" and related events which are the subject of this hearing.

WHEREFORE Intervenor TMIA respectfully requests that the Chairman of the Licensing Board issue a Subpoena Duces Tecum in the form attached hereto directing Mr. Faust to produce the requested documents, at his September 21, 1984 deposition.

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Respectfully submitted,

,%& ' Abb hnne Doroshow 24 North Capitol Street Washington, D.C. 20002 (2C2)-797-8106 dM w Lynrla Bernabei Govprihnent Accountability Project 155 5 ConnecticutAve. N.W.-

Was bp ton, D.C. 20036 (202) 232-8550

- Dated: September 10, . 1984 Attorneys for Three Mile Island Alert L1

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' UNITED STATES OF AMERICA ('

NUCLEAR REGULATCRY COMMISSION

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'Before the ' Atomic Safety and Licensing Board y

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In!the Mattbr' of. ;Y )

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METROPOLITAN EDISION COMPANY ~ )- Docket No. 50-289 q- 1.y m ) (Restart-Management-

"' (Three Mile Island Nuclear ) Phase)

' Station, Unit 1) )

m SUBPOENA DUCES TECUM THE NUCLEAR REGULATORY COMMISSION - AND IVAN W. -SMITH, CHAIRMAN,

.; ATOMIC SAFETY AND dICENSING BOARD, TO: Craig Faust,-currently within Licensee's employ, at the Three Mile Island Nuclear.

-Station,'Middlehown, PA.

YOU ARE HEREBY COMMANDED to produce -the following documents

'G c y ,at your; deposition on- Friday, September 21, 1984, - at 2:30 p.m.

.at-the Friends Meeting House, 6th and Herr Streets (1100 6th

-(rni

( _ St.), Harrisburg, PA, -17102:

V p;. 1. All personal' notes, logs, diaries, and any other documents contained in your. personal- file,' concerning i: . .

the dates of March 28, March 29, and March 30, 1979.

2. All interviews in' your possession. which: were taken -

' concerning the' March 28, 1979 accident.

3. All- correspondence and other written communications

%. - between you and General Public Utilities,- Metropolitan r

Edison Company, GPU Service Corporation, GPU Nuclear i.

Corporation or Group, Pennsylvania Electric Company, or

-Jersey Central Power and Light Corp., or employees 1

,r.

_ ; thereof regarding the dates of March 28, March 29 or

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i March 30, 1979.

.4. All correspondence and othir written communications i' between ~you and General Public Utilities, Metropolitan

. Edison ~ Company, GPU Service Corporation, GPU Nuclear

. Corporation or Group, Pennsylvania Electric Company,. or Jersey ~ Central Power and Light Corp., or employees thereof regarding reporting of information during the March 28, 1979 accident to the NRC or the Commonwealth

of Pennsylvania.

You have been subpoenaed by Intervenor Three Mile Island

' Alert, Inc.

Pursuant to. the Commission's regulations at 10 CFR 2.720' (f), on motion made by you promptly, and in any event before 2:30 p.m.,. on September 21, 1984, and on notice to attorney for Intervenor, the Chairman of. the Atomic Safety and Licensing Board, or, if he is unavailable, the Commission may (1) quash or

- modify .the -Subpoena if it is unreasonable or. requires evidence not.- relevant to any matter in issue, or (2) condition denial of the motion on just.and reasonable grounds. ~

'YOU ARE HEREBY NOTIFIED THAT ANY FAILURE TO OBEY THIS SUBPOENA MAY BE DEEMED A CONTEMPT AND APPROPRIATE SANCTIONS MAY

.BE ORDERED.

DATED THIS d

'ay of , 1984.

ATOMIC SAFETY AND LICENSING BOARD

-By Ivan W. Smith, Chairman 2 -

- . - - _ . ,

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