ML20214W630

Forwards Subpoena for Deposition of RA Meeks to Appear in Washington,Dc on 870615.Certificate of Svc Encl.Related Correspondence

ML20214W630
Person / Time
Site:	Three Mile Island
Issue date:	06/05/1987
From:	Doris Lewis GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Meeks R EG&G, INC.
References
CON-#287-3714 CIV-PEN, EA-84-137, NUDOCS 8706160110
Download: ML20214W630 (2)

Text

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oAwo n. uwis June 5, 1987 ,,$"^g,3, Mr. Ronald A. Meeks .

DOE Inspection General EG6G Inc., WCB-E2, Room 230 P.O. Box 1625 Idaho Falls, Idaho 83415 In the Matter of GPU Nuclear Corporation (ThreeMileIslandNuclearStation, Docket No. 50-320; EA 84-137Unit - dW2g6 /

Dear Mr. Meeks:

Please find enclosed the original subpoena for your deposi-tion in the above captioned proceeding. Per agreement with NRC counsel, this registered letter constitutes service of the sub-poena. Also enclosed is a copy of the subpoena for your signa-ture to acknowledge receipt. Please sign and date the acknowl-edgement copy of the subpoena and return it to us in the envelope provided.

The deposition is scheduled for Monday, June 15, 1983, .

starting at 9:30 a.m., at the Offices of Shaw, Pittman, Potts and 3

Trowbridge, 2300 N Street N.W., Washington, D.C. 20037. The dep-osition will be conducted under oath before and transcribed by a

! Notary Public from Ace-Federal Reporters, Inc.

As GPUN has discussed with NRC counsel, because of the pos-sibility that you may be in Washington D.C. on government busi-ness at the time of the deposition, it is not presently possible to tender fees for travel expenses with this subpoena. Instead, at the time of the deposition, GPUN will arrange to reimburse travel expenses you personally incur, up to the applicable lim-its.

Sincerely, YDY O hhQ David R. Lewis Counsel for GPUN Enclosure

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O e

UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION Before the Administrative Law Judge In the Matter of )

)

GPU Nuclear Corporation ) Docket No. 50-320

) License No. DPR-73

) EA-84-137 (Three Mile Island Nuclear )

Station, Unit No. 2) )

CERTIFICATE OF SERVICE I hereby certify that the subpoena dated May 8, 1987, for the deposition of Ronald A. Meeks, and the letter from D. Lewis to Ronald A. Meeks dated June 5, 1987, were served by registred mail on Mr. Meeks, this 5th day of June 1987. 'I also certify that copies of the aforementioned documents were served by depos-it in the United States Mail, First Class, postage prepaid, this 5th day of June, 1987, to the following persons:

Ivan Smith, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

! George E. Johnson, Esquire Office of the General Counsel 9604 MNBB U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

David R. Lewis f Dated: June 5, 1987

, -. - - -- ,~ ..- . - - . - - - - - . - - - - _ , , - - - - - , - - - - - . - - . - - - - , - - , - - , - - , - - - - - . , - - - - - - -

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- 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

Administrative Law Judge

, Ivan W. Smith i

In the Matter of ) .

)

GPU Nuclear Corporation ) Docket No. 50-320

) EA 84-137 (Three Mile Island Nuclear )

Station, Unit No. 2) )

SUBPOENA In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. I 2201(c) (1982), and 10 C.F.R. I 2.720, Ronald A.

Meeks is hereby ordered to attend and give testimony at deposi-tion upon oral examination by counsel for GPU Nuclear Corporation

' in the above captioned proceeding. The deposition will be held at a mutually convenient time and location, but no later than

, 1987. The deposition will be conducted before a Notary Public. Ronald A. Meeks is further ordered to produce at the deposition all notes, memoranda, files, and other documents in his possession, custody, or control relating to Mr. Richard Parks, allegations made by Mr. Parks, or investigations of such allegations.

On motion made promptly, and in any event at or before 1987, and on notice to GPU Nuclear Corporation, the Presiding Officer (cr if the Presiding Officer is unavailable, b' d.

T

, - - ,. . - _ , - - - - - - _ . . _ - , _ _ ~ - , _ _ _ - . _ _ . _ _ _ __ . . , ._

the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reason-able terms. A copy of the order designating the issues in this proceeding is attached.

IT IS SO ORDERED. .

Ivan W.(Smith Administrative Law Judge Dated Bethes aryland this day o , 1987. .

P e

s DOCMETED UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COPMIS b U N E N ADMINISTRATIVE LAW JUDhCkET d$E v!bf.

Ivan W. Smith BM" saya aus/p986 In the Matter of Docket No. 50-320 General Public Utilities Nuclear License No. DPR-73 Corporation EA 84-137

) [ASLBPNo. 86-534-01-OL]

(Three Mile Island, Unit No. 2) (Civil Penalty)

August 13, 1986 MEMORANDUM AND ORDER FOLLOWING PREHEARING CONFERENCE Counsel for General Public Utilities and Counsel for the NRC Staff l

l joined me in a prehearing conference at Bethesda, Maryland on July 30, 1986.

Discovery is authorized to begin innediately. The parties and I have agreed that discovery may be had under the following broad issues:

1. Whether the NRC is barred from imposing a civil penalty in this proceeding due to the dismissal with prejudice of the Department of Labor proceedings charging discrimination against Parks.

. 2. Whether Parks' replacement as Alternate Startup and Test I Supervisor on February 23, 1983 constituted retaliation against Parks contrary to 10 CFR 5 50.7.

3. Whether Parks' interview by Messrs. Hofmann and Wheeler on l

March 14, 1983 constituted retaliation against Parks contrary to 10 CFR S 50.7.

o r A c. 3 , A , , o 4(&J - p% ( j

4. Whether Parks' removal as the primary Site Operations Department representative on the Test Working Group for the polar crane project on March 17, 1983 was involuntary and, if so, whether it constituted retaliation against Parks contrary to 10 CFR $ 50.7.

5. Whether Parks' placement on leave of absence with pay on March 24, 1983 constituted retaliation against Parks contrary to 10 CFR l 50.7. '

6. Based on resolution of the issues (1)-(5) above: .

a. whether Licensee violated NRC requirements as set forth in the Notice of Violation and Proposed Imposition of ,

Civil Penalty issued on August 12, 1985; and

b. whether, on the basis of such violation, the March 4, 1986 Order Imposing Civil Penalty should be sustained.

Discovery, including answers to discovery requests, should be l completed by February 1,1987.

The parties should prepare for an evidentiary hearing in the Spring a of 1987. Further prehearing requirements will be addressed in subsequent orders.

f J/ M Ivan W. Smith ADMINISTRATIVE LAW JUDGE Bethesda, Maryland i August 13, 1986

I harsby acknowledge receipt of this subpoena.

Ronald A. Meeks Date

c. .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Administrative Law Judge' Ivan W. Smith In the Matter of )

)

Docket No. 50-320 GPU Nuclear Corporation )

) EA 84-137 (Three Mile Island Nuclear )

Station, Unit No. 2) )

SUBPOENA .

In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. I 2201(c) (1982), and 10 C.F.R. I 2.720, Ronald A.

Meeks is hereby ordered to attend and give testimony at deposi-tion upon oral examination by counsel for GPU Nuclear Corporation in the above captioned proceeding. The deposition will be held at a mutually convenient time and location, but no later'than '

t

! , 1987. The deposition will be conducted before a Notary Public. Ronald A. Meeks is further ordered to produce at the deposition all notes, memoranda, files, and other documents in his possession, custody, or control relating to Mr. Richard Parks, allegations made by Mr. Parks, or investigations of such allegatio s.

l On motion made promptly, and in any event at or before 1987, and on notice to GPU Nuclear Corporation, the l

Presiding Officer (or if the Presiding Officer is unavailable, l / e , ~ ,M

.w 1-

_;g.._ __ ___ _ _ _ ___ _ _ _ _ _-- ._. _ _-_-

e the Commission) may (1) quash or modify the subpoena if it is

-7 .-

unreasonable'or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reason-able terms. A copy of the order designating the issues in this proceeding is attached. .

IT IS SO ORDERED.

i Ivan W./ Smith Administrative Law Judge Dated Bethes aryland this day o , 1987. .

.o 00CNETED UNITED STATES OF AMERICA .

- NUCLEAR REGULATORY COP 9tISbU N E M ADMINISTRATIVE LAW BilA JUDNTb'[INPV!f E"

Ivan W. Smith gets Aus/p988 1

In the Matter of '

l l Docket No. 50-320 General Public Utilities Nuclear License No. DPR-73 Corporation lll EA 84-137

/ [ASLBPNo. 86-534-01-0L]

(Three Mile Island, Unit No. 2) ,

1 (Civil Penalty)

J August 13, 1986 MEMORANDUM AND ORDER FOLLOWING PREHEARING CONFERENCE Counsel for General Public Utilities and Counsel for the NRC Staff joined me in a prehearing conference at Bethesda, Maryland on July 30, 1986.

Discovery is authorized to begin imediately. The parties and I have agreed that discovery may be had under the following broad issues:

i

1. Whether the NRC is barred from imposing a civil penalty in this proceeding due to the dismissal with prejudice of the Department of Labor proceedings charging discrimination against Parks.

i

2. Whether Parks' replacement as Alternate Startup and Test Supervisor on February 23, 1983 constituted retaliation against Parks contrary to 10 CFR i 50.7.

3. Whether Parks' interview by Messrs. Hofmann and Wheeler on March 14, 1983 constituted retaliation against Parks contrary to l

10 CFR 9 50.7.

7602'/90 0 '/ ,

4. lAiether Parks' removal as the primary Site Operations Department representative on the Test Working-Group for the polar crane project on March 17, 1983 was involuntary and, if so, whether it constituted retaliation against Parks contrary to 10 CFR 5 50.7.

5. Whether Parks' placement on leave of absence with pay on March 24, 1983 constituted retaliation against Parks contrary to 10 CFR I 50.7. ,

~

6. Based on resoldtion of the issues (1)-(5) above: ,

a. whether Licensee violated NRC requirements as set forth in the Notice of Violation and Proposed Imposition of Civil Penalty issued on August 12, 1985; and

b. whether, on the basis of such violation, the March 4, 1986 Order Imposing Civil Penalty should be sustained.

Discovery, including answers to discovery requests, should be completed by February 1,1987.

The parties should prepare for an evidentiary hearing in the Spring s of 1987. Further prehearing requirements will be addressed in -

subsequent orders.

BM Ivan W. Smith ADMINISTRATIVE LAW JUDGE Bethesda, Maryland August 13, 1986 I

_ _ _ _ _ . _ _ _ _ _ _ _ _