ML19332A039
| ML19332A039 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/03/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8009100431 | |
| Download: ML19332A039 (5) | |
Text
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E UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION 2
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78 BEFORE THE ATOMIC SAFETY AND LICENSING BO S
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In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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LICENSEE'S MEMORANDUM TO ATOMIC SAFETY AND LICENSING BOARD On August 27, 1980, Mr. Sholly served on the Board and Licensee's counsel a document entitled "Intervenor Steven C.
Sholly Request to Licensee for Supplementation of Discovery Requests and Discovery Requests Based on New Information Con-tained in Article in 'TMI Today' Received 8/26/80."
In brief, Mr. Sholly requests that Licensee supplement its previous re-sponses to interrogatories, and that the Board grant leave for additional interrogatories, both relating to human factors engineering of the control room.
Mr. Sholly's requests were based on a recent article appearing in "TMI Today" describing a program undertaken by Licensee involving the use of a mock-up located in the TMI-l turbine building.
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In telephone discussions yesterday with Mr. Sholly, Licensee's counsel advised Mr. Sholly, without taking a posi-tion on the merits of Mr. Sholly's requests, that Licensee would in any event be unable to comply with the requests in time to assist Mr. Sholly in the preparation of direct testi-many on his Contention 15.
In these circumstances Mr. Sholly concluded that his purposes would be better served by an early opportunity to inspect the control room mock-up.
Accordingly, Licensee has made arrangements for Mr. Sholly to inspect the mock-up later this week, and Mr. Sholly has authorized Licensee's counsel to advise the Board that his August 27, 1980 requests are withdrawn.
Respectfully submitted, SEAW, PI MAN, POTTS & TROWBRIDGE By J/7h
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George F. Trowbridge Dated: September 3, 1980 m
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Memo-randum to Atomic Safety and Licensing Board," dated September 3, 1980, were served upon those per' sons on the attached Service List by deposit in the United States mail, postage prepaid, this 3d day of September, 1980.
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[ George b'. Trowbr[dge Dated: September 3, 1980 3
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UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 30ARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Ltation, Uniu No. 1)
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SERVICE LIST Ivan W.
Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm' Soard Panel Post Office Sox 3265 U.S. Nuclear Regulatory Com=ission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Karin W.
Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Sox 2357 881-West Ourer Drive Harrisburg, Pennsylvania 17120 Cak Ridge, Tennessee 37530 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County 3 card Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 i
James R. Tourtellotte, Esquire (4)
Walter W.
Cohen, Esquire Office of the Executive Legal Director - Consumer Advocate U.
S. Nuclear Regulatory Commission Office of Consumer Advocate i
Washington, D.C.
20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (3)
Office of the Secretary i
U. S. Nuclear Regulatory Commission Washington, D.C.
20555 i
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+ Jordan D.
Cunningham, Esquire William S.. Jordan, III, Esq.
Attorney for Newberry Township Attorney for People Against Nucle T.M.I.
Steering Committee Energy 2320 North Second Street Earmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W.
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Theodore A. Adler, Esquire Widoff Reager Selkowitz & Adler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned.
Judith H. Johnsrud Scientists Environmental Coalition on Nuclei Harmon & Weiss Pcwer 1725 Eye Street, N.W.
433 Orlando Avenue Washington, D.C.-
20006 State College, Pennsylvania 168(
Steven C.
Sholly Marvin I. Lewis 304 South Market Street 6504 3radford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 1914:
Gail Bradford Marjorie M. Aamodt Holly S. Keck R.
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5 Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 -West Philadelphia Street York, Pennsylvania 17404 f
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