ML20073T051

Application for Issuance of Encl Unsigned Subpoenas Directing Attendance & Testimony of I Souders & J Ogsbury at ASLB 830523 Session in Rockford,Il.Certificate of Svc Encl

ML20073T051
Person / Time
Site:	Byron
Issue date:	05/06/1983
From:	Whicher J DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	Ogsbury J, Souders I AFFILIATION NOT ASSIGNED
References
NUDOCS 8305100286
Download: ML20073T051 (7)

Text

.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO) O g

/.

BEFORE THE ATOMIC SAFETY AND LICENS G B04kD- g

• a +.;;gt

~

Af4y0  :

2! 0 -12 IN THE MATTER OF ) ' fp08A '

) o3%,y

&&,75, %

COMMONWEALTH EDISON COMPANY 7

)

)

Docket 50Y'4 (Byron Station, Units 1 ) o's773D1;$#-

and 2) )

JOINT INTERVENORS' APPLICATION FOR ISSUANCE OF SUBPOENAS The Rockford League of Women Voters and DAARE/ SAFE, by their undersigned attorney, hereby request, pursuant to 10 CFR S2. 720, subpoenas directing the attendance and testimony of Irvin Souders and Junius Ogsbury at the next session of the Licensing Board

• in this operating license proceeding.

I In support of this Application, Jane M. Whicher, attorney for the League and DAARE/ SAFE in the issue of Quality Assurance /

Quality Control, makes the following representations to the Board, under oath, on information and belief:

1. During the past week, at the reques t of John Hughes ,

she has had telephone conversations with Mr. Souders and Mr.

• The date of May 23, 1983 has been entered on the attached

subpoenas. It is contemplated that Mr. Souders and Mr.

Ogsbury will testify after John Hughes' testimony is presented and that the actual date of appearance can be agreed to informally by all concerned.

8305100286 830506 e-PDR G

ADOCK 05000454 ppg 9

([)

I L _

Ogsbury. Both Mr. Souders and Mr. Ogsbury were employed by Pittsburgh Testing Laboratory at Byron to inspect work done by Hatfield Electric Company. Mr. Ogsbury was at Byron from May through December 1982. Mr. Souders was at Byron during the fall of 1983 until January of 1983. Neither are presently employed at Byron, but both are presently working in the nuclear industry.

2. Mr. Souders indicated that, if called as a witness, he would testify that he has a background in nuclear, and other, quality assurance work; that he observed poor welding quality; that he was requested to sign documentation indicating that certain installations were complete and per drawings without having seen the installations; that he was requested to " buy off" weld travellers which were incomplete; and that he witnessed an incident concerning Mr. Hughes' certification testing by Hatfield during which Mr. Hughes was given the answers to a test which he had failed and then was retested with the answers i

before him.

3. Mr. Ogsbury indicated that, if called as a witness, he would testify that he was lead welding inspector; that he has a background in nuclear, and other, types of inspection work; that material fabricated by Systems Control Corporation was found, after installation, to have deficient welds and to have been made of undersized steel; that methods of inspecting and documenting welds were inadequate; and observed a brace welded to a pressure pipe.

t l _

4. Both Mr. Souders and Mr. Ogsbury have informed Ms. Whicher that they would not appear and testify voluntdrily, but would appear and testify if subpoened.

Accordingly, Joint Intervenors request the issuance of the attached subpoenas.*

DATED: May 6, 1983 Respectfully submitted, .

i 90 t. U L k, l Jane M. Whicher, One of the attorneys for the Rockford League of Women Voters and DAARE/ SAFE in the issue of quality assurance / quality control l

Subscribed and sworn before me this M day of May, 1983.

. V W6tary Public Jane M. Whicher 109 North

Dearborn,

1. 1300 Chicago, IL 60602 (312) 641-5570

• The addresses for service on each subpoena have been lef t blank on each subpoena. Counsel is presently attempting to ascertain addresses for service on Mr. Souders and Mr. Ogsbury.

D

~

3initch &ates af Amerita NUCLEAR REGULATORY COhDilSSION n

v In the matter of: '

Commonwealth Edison Company (Byron Station, Units 1 and 2)

>- DOCKET NO. 50-454 50-455 TO d

YOU ARE HERE3Y COhDIANDED to appear a,t ,,ghg,,,Fp,d,e,gg,1,,,Qg.u,E,q,,,B,gi,k, ding ,

. 9.r,,,,s,y,c,b,,g,thg r..1 gg.a,gign,. a s,..ths,,,gg a.r.d..mu..hs...n1.tting..... .... ........ ...

m the city a f ..Ro.c..k...fo rd...,....I..l...l..in..o..i s

o n the....... 2,3,,r,d... day o f.....U.ay,,,,,,,,,,,,,,,,,,,,,,19,,@,3,,,,,,3 e,,, ,,,2,3,0,0.... .. 0'clo ek P . 31 to testify on behalf of ....I.n,t,gy,y,e,n,9,r,s,,,,,,t,h,e,.,Rp,g,kf,gg,d ,1gaggg,,p f,,yp, men,,, ,,,,

Voters and DAARE/ SAFE in the above entitled action and bring with you the document (s) or object (s) described in the attached schedule.

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD BY Jane M. Whicher ATTOR,NEY FOR Rockford League of Women Voters and . . . . . . . , . . . . . . . . . ...,,....19.,..., ...

UAARE/ SAFE -

TE1.EFHONE M12 T 641-5570 -

to C.E.R.1.7 0 (t) p,es,ain, orjuer 0,. ,f he i, ,,va,tasie, ene on morion made promptly, and in arsy ownt Communon may (1) quasn or mod:fy the sub-6t or before the rime specafled in the 21sbootne poene af it is unressonette or requsret ersdence for compliance by the perton to whom the sub-not relevant to one matter in i,true. or (:) con =

porna at directed and on nonce to the pp et ditton dennal of the monon on just sad reasonable "ote intsante the rappeene weg gg;ueg, ryg qq,mg, n

~

Mnitch &:ates of America NUCLEAR REGULATORY COhBilSSION v

In the matter of:

• Commonwealth Edison Company ). DOCKET NO. 50-454 (Byron Station, Units 1 and 2) 50-455 TO Irvin Souders M

YOU ARE HEREBY COhutANDED to appear #.t...tha..f.e.dcLal...C.Qur1..Epilding, 9.r..#.wh.. 9.tb.9.r..ls.c.ario.n...u...Ihe..Epaxd..may..he..sitring..................... ...

in the ct' ry o f .....Ro...c..k..f..o...r.

, .. d...,....I

.. .l..l..i.n...o..i..s o n th e..... 2,3 5,d..... day o f..........!.I.ay,,,,,,,,,,,,,,,,,19,,p,3......a t....

2,j,9,0......... 0'clo ek P . 3{,

to testify on behalf of ..I.n,t.e,r,y,e,n,9,r,s,,,,,t,he,,,R,9,g,k,fp,r.d,,,Le, ague,,,p,f ,V,9,ggn:,,,,,,_,

Voters and DAARE/ SAFE .

in the above entitled action and bring with you the document (s) or object (s) described in the attached schedule.

BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD BY Jane M. Whicher ATTOR.NEY FOR Rock ford League n f Women Voters and "'""~"'""'"""'""~'39" " " ~ " '

DAARE/ SAFE -

TEI.EPHONE r 312) 641-5570 .

t0 C.E.R.1.710 (t} p,,,,oin, office,o, ,7 he ,,une,,g.,,ia, ,n, On motion made promptly. and in any ownt Commuston may (1) quwt or mocfy rne sub-et or before the nme speelfied in the itsbooena poene if st is unressonable or requerrs ersdence for ccmolance by the person to wnom the sub- not relevent to anv matter in Ltsue, or (.') can.

90ene

• 0

is directed. end on nonce to the w et dinon dennal of the monon on just and reasonable

• • !Tanet the su bpoeng mg gg;ygg, gn, ,,,mg, n-

1 SERVICE LIST

• Ivan W Smith, Chairman .

Administrative Judge Steven C. Goldberg, Esq.

Atomic Safety and Licensing Board U.S. NuclearD.C.

Regulatory Commission Office of the Regulatory U.S. Nuclear General Counsel Washington, 20555 Commission Washington , D. C.

20555 i Dr. A. Dixon Callahan Administrative Judge Office of the Secretary of Union Carbide Corporation the Commission d

P.O. Box Y ATTN: )

Oak Ridge, Tennessee Docketing & Service ~

38730 Section U.S. Nuclear Regulatory Commission 1 Washington, D. C. 20555 i

Dr. Richard F. Cole Administrative Judge I

Atomic Safety and Licensing Board David Thomas, Esq.

U.S. Nuclear Regulatory Commission 77 South Wacker Chicago, IL Drive Washington, D.C. 20555 60621 i -

Alan P. Bielawski, Esq.

i 1

Isham Lincoln & Beale Joseph Gallo, Esq.  :

Three First Chicago, IL National Plaza Isham Lincoln & Beale 60603 1120 Connecticut Avenue, N.W.

Room 325 Washington, D.C. 20036  :

1

• By Federal Express. = =

first class postage prepaid. Remainder served by United States mail,

~-

CERTIFICATE OF SERVICE ,

I certify that 1 served copies of Joint Intervenors' Application for Issuance of Subpoenas on each person on the attached service list as indicated on the attached list, on May 6, 1983.

\ '

~e E .

A '

Jane M. Whicher I -

One of the attorneys for the Rockford League of Womeu Voters and DAARE/ SAFE on the issue of Quality Assurance / Quality Control Dated: May 6, 1983 e