ML20097D246

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

ML20097D246
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
ML20097D126	List: ML20097D125 ML20097D133 ML20097D144 ML20097D147 ML20097D152 ML20097D159 ML20097D167 ML20097D177 ML20097D187 ML20097D192 ML20097D208 ML20097D215 ML20097D225 ML20097D234 ML20097D243 ML20097D246 ML20097D250 ML20097D264 ML20097D281 ML20097D317 ML20097D327 ML20097D347 ML20097D353 ML20097D363 ML20097D373 ML20097D390 ML20097D406 ML20097D421
References
SP, NUDOCS 8409170423
Download: ML20097D246 (5)

Text

e .. :a - - .

m r-03r.?u.

84 SEP 14 A9:34 ~l TMIA 9/10/84 0CC3C WiiSU'E UNITED STATES OF AMERICA BRANCH 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 Leland Rogers, of 1045 Church St., Landisville, PA, 17538, formerly of B&W, for the purpose of requiring the above-named

. individual to produce documents at the deposition scheduled to commence in this matter on September 20, 1984 at 1:30 p.m. A copy of the proposed Subpoena is attached.

The documents of Mr. Rogers 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. Rogers to produce the requested documents, at his September 20, 1984 deposition.

0409170423 940911 .

PDR ADOCK 05000299 PM g

. Respectfully submitted,

[ DC\,M M DW

>Jdanne Doroshow If324 North Capitol Street Washington, D.C. 20002 (202)-797-8106-

[f\ d d ^-

Lynn\Bernabei Goverranent Accountability Project 15 'ConnecticutAve.. N.W.

Washington, D.C. 20036 (202) 232-8550

, Dated: September 10, 1984 Attorneys for Three Mile Island Alert

p. < > m  ;; . ,

UNITED STATES OF AMERICA '

NUCLEAR' REGULATORY COMMISSION 1Before the Atomic Safety and Licensing Board

-In the Matter of )

)

METROPOLITAN EDISION COMPANY ) Docket No. 50-289

) (Restart-Management L(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: Leland Rogers, 1045 Church S t. , Landisville, PA, 17538:

YOU ARE HEREBY COMMANDED to produce the following documents at your scheduled to commence Thursday, September 20,1984, at 1.3 0 p.m. 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

m- .

4 March 30, 1979.

4. All correspondence and ot'ie.- 'irhtet. co.nmunications 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 ta) the Commission's regulations at 10 CFR 2.720 (f), on motion made by you promptly, and in any event'before 1:30 p.m. on September 20, 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

s. . -

-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 19, 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 .

i e