ML20097F163
| ML20097F163 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/14/1984 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| SP, NUDOCS 8409180410 | |
| Download: ML20097F163 (6) | |
Text
.1T)
,vm
~.
i September [4, 1984
'81 SEP 17 F12:21 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SS[
)
(Restart Remand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
LICENSEE'S REQUEST TO MODIFY TMIA'S SUBPOENAS DUCES TECUM On or about September 11, 1984, TMIA served Notices of Depo-sition or Subpoenas on the following employees or ex-employees of GPU and B&W:
John Herbein Herman Dieckamp Robert C. Arnold Gary Miller George Kunder Michael Ross Craig Faust Hugh McGovern Ivan Porter Brian Mehler Theodore Illges Leland Rogers Joseph Chwastyk John Flint Licensee has also received copies (unsigned) of Subpoenas Duces Tecum for each of these individuals.
Each Subpoena Duces Tecum 8409180410 840914 PDR ADOCK 05000289 G
PDR 7 503
requests the individual in question to produce at the deposition the following documents:
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 com-munications between you and General Public Utilities, Metropolitan Edison Company, GPU Service Corporation, GPU Nuclear Cor-poration or Group, Pennsylvania Electric Company, or Jersey Central Power and Light Corp., or employees thereof regarding the dates of March 28, March 29 or March 30, 1979.
4.
All correspondence and other written com-munications between you and General Public Utilities, Metropolitan Edison Company, GPU Service Corporation, GPU Nuclear Cor-poration or Group, Pennsylvania Electric Company, or Jersey Central Power and Light Corp., or employees thereof regarding re-porting of information during the March 28, 1979 accident to the NRC or the Com-monwealth of Pennsylvania.
Pursuant to 10 CFR 2.720(f) Licensee requests the Licensing Board to modify the Subpogna Duces Tecum as follows:
1.
Consistent with the protective order granted by the Board's Memorandum and Order dated August 31, 1984, and on the ground that many of the documents sought to be produced would in-volve evidence not relevant to any matter in issue, Licensee re-quests that each Subpoena Duces Tecum (except as to Mr. Dieckamp) be modified to limit the documents to be produced to those J
relating to the pressure spike, the initiation of core spray or the generation and subsequent combustion of hydrogen which oc-curred at TMI-2 on March 28, 1979.
With respect to Mr. Dieckamp, Licensee requests that the Subpoena Duces Tecum be modified to limit the documents to be produced to those relating to Mr.
Dieckamp's knowledge of the conditions of the reactor or events occurring during the accident.
2.
On the ground that the Subpoenas Duces Tecum are unrea-sonable, Licensee requests that they be modified so as not to re-quire the further production of any documents which have already been provided to TMIA for inspection and copying in response to TMIA document requests and interrogatories.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Af}f/
, /b W J
Gdorge/F. ' Trokbridge, PA.
Ernest L. Blake, Jr., F.C.
Counsel for Licensee Dated: September 14, 1984 September 14, 1984 UNITED STATES OF AMERlCA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart Remand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Request to Modify TMIA's Subpoenas Duces Tecum," dated September 14, 1984, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 14th day of September, 1984.
h./
x&
J/
Tro' bridge, P/C.
Gborgg F.
w Dated: September 14, 1984
- - ~.
1
- Administrative Judge Mr. Henry D. I.ukill Gustave A. Linenberger, Jr.
Vice President Atcmic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.
20555 Middletown, PA 17057 Docketing and Service Section (3)
Mr. and Mrs. Norman Aamodt Office of the Secretary R.D.
5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C.
20555 Ms. Louise Bradford Atomic Safety & Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C.
20555 Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.
20002 Washington, D.C.
20555
- Lynne Bernabei, Esq.
^
- Jack R.
Goldberg, Esq. (4)
Pr ct Office of the Executive Legal 1555 Connecticut Avenue U.S N c ear Regulatory Commission Washington, D.C.
20009 Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Harmon, Weiss & Jordan Thomas Y. Au, Esq.
2001 S Street, N.W., Suite 430 Office of Chief Counsel Washington, D.C.
20009 Department of Environmental Resources Michael F. McBride, Esq.
505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O.
Box 2357 1333 New Hampshire Avenue, N.W.
Harrisburg, PA 17120 Suite 1100 Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, VA 23212 O
b_
5 s-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart Remand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J.
Palladino, Chairman Administrative Judg.e U.S. Nuclear Regulatory Commission John H.
Buck Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Thomas M.
Roberts, Commissioner U.S. Nuclear Regulatory Commissior U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge James K. Asselstine, Commissioner Christine N.
Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commission Frederick Bernthal, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Administrative Judge Ivan W.
Smith, Chairman Lando W.
Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge
- Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 W0shington, D.C.
20555 n