ML20097D363

Application for Issuance of Subpoena Duces Tecum to Rc Arnold Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence

ML20097D363
Person / Time
Site:	Three Mile Island
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
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References
SP, NUDOCS 8409170459
Download: ML20097D363 (4)

Text

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'84 SEP 14 A9 0S)

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,, TMIA 9/10/84 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 ) Phase)

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 and Licensing Board for the issuance of a Subpoena Duces Tecum to Robert C. Arnold, enployee of GPU,- for the purpose of requiring the above-named individual to produce documents at the

' deposition scheduled to commence in this matter on September 26, 11984 at 9:30 a.m. A copy of the proposed Subpoena is attached.

The documents of Mr. Arnold, who was a senior corporate

_of ficer the day of the _TMI-2 accident, 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. Arnold to produce the requested documents, at his September 26, 1984 deposition.

B409170459 840911 PDR ADOCK 05000289

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Respectfully submitted, M' f (Q%

,J anne Doroshow w~

/

24 North Capitol Street ashington, D.C. 20002 (202)-797-8106

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Lynft Bernabei Goye ment Accountability Project 1545- ConnecticutAve. : N.W.

Washington, D.C. 20036 (202) 232-8550 Dated: September 10, 1984 ' Attorneys for_ Three Mile Island

, Alert b

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s. - .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION a i

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

)

METROPOLITAN EDISION COMPANY ) Docket No. 50-289

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

Station, Unit 1) )

SUBPOENA DUCES TECUM THE _ NUCLEAR REGULATORY COMMISSION AND IVAN W. SMITH, CHAIRMAN, ATOMIC SAFETY AND LICENSING BOARD, TO: Robert C. Arnold, currently within _the employ of GPU, 100 Interpace Parkway, Parsippany, New Jersey, 07054.

YOU ARE HEREBY COMMANDED to produce the following documents at your deposition' scheduled for Wednesday, September 26, 1984, at-9:30 a.r.. at the Friends Meeting House, 6th and Herr Streets (1100 6th St.),' Harrisburg, PA, 17102:

1. All personal notes, logs, diaries, and any other documents contained in your personal file, concerning 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 Edison Company, GPU_ Service Corporation, GPU Nuclear Corporation or Group, Pennsylvania Electric Company, or Jersey Central Power and Light Corp., or employees thereof regarding the dates of March 28, March 29 or I

-March 30, 1979.

4. All- correspondence and other 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 9:30 a.m., on September 26, 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 day of , 1984.

ATOMIC SAFETY AND LICENSING BOARD By Ivan W. Smith, Chairman 2 .

_