ML20098G471

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Application for Issuance of Subpoena Duces Tecum to W Creitz to Appear & Produce Documents for 841010 Deposition Re Dieckamp Mailgram Issue & Related Events.Related Correspondence
ML20098G471
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/01/1984
From: Bernabei L, Doroshow J
GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20098G446 List:
References
SP, NUDOCS 8410050030
Download: ML20098G471 (2)


Text

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,g TMIA - 10/1/84

-- 0%KETED ChnC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION T4 DCT -4 A10:40 Before the Atomic Safety and Licensing: Board ECat 1.

00L.tLilNU & SEPV Q BRANCH

.In'the Matter of )

)

METROPOLITAN EDISON COMPANY ). Docket No. 50-289

) (Restart-Management Phase)

(Three' Mile Island Nuclear )

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 ("TMIA") applies to the Atomic Safety and Licensing Board for the issuance of a Subpoena Duces Tecum to Walter Creitz, Presi~ dent of-Met-Ed at the time of the accident but currently not within the employ of licensee, for

.the purpose of requiring the above mentioned individual to appear

.and produce documents for a deposition scheduled to commence in this matter on October 10, 1984, at 1:30 p.m. A copy of the proposed Subpoena is attached.

Mr. Creitz's testimony and the documents requested are related to the Dieckamp mailgram issue and related events which are the subject'of this hearing. Specificially Mr. Creitz as President of Met-Ed on March 28, 1979, directed Mr. Herbein to station hemself at the site and according to Mr. Herbein's testimony in his deposition of September 28, 1984, discussed with Mr. Dieckamp the'TMI-2 accident on March 28, 1979.

WHEREFORE Intervenor TMIA respectfully requests that the chairman of the Licensing Board issue a Subpoena Duces Tecum in 0410050030 841001 PDR ADOCK-05000289 PDR Q

h. -

y th5 form attached hereto directing Mr.-Creitz to appear for a depocition-and to produce the documents listed in the cubpoena.

at-his October 10, deposition.

Respectfully Submitted,

%w v \ {u%-l( b' Joanne Doroshow 1324 North Capitol Street Washington, D.C. 20002

-(202)-797-8106

L e Wcd .

- Lynhe'Bernabei Gov rnment Accountability Project 15 Connecticut Avenue, N.W.-

W(as ington, D.C. 20002 (202) 232-8550 DATED: October 1, 1984 Attorneys for Three-Mile Island Alert

.