ML20005C045
| ML20005C045 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/12/1981 |
| From: | Aamodt M, Adler R, Blake E, Bradford L, Clewett J, Cole D, Doroshow J, Mcbride M, Swartz L AAMODTS, AFFILIATION NOT ASSIGNED, CLEWETT, J., LEBOEUF, LAMB, LEIBY & MACRAE, METROPOLITAN EDISON CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD), PENNSYLVANIA, COMMONWEALTH OF, THREE MILE ISLAND ALERT |
| To: | |
| Shared Package | |
| ML20005C042 | List: |
| References | |
| NUDOCS 8111180319 | |
| Download: ML20005C045 (6) | |
Text
i
. UNI' dD STATES OF AMERICA N,UCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.)
In the Matter of
)
DOCKET No. 50-289
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METROPOLITAN EDISON COMPANY
)
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(Res tart)
(Three Mile Island Nuclear
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(Reopencd Proceeding)
Station, Unit I)
)
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STIPULATION The parties to this reopened proceeding, on their
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own behalf or by counsel, as indicated below, stipulate that 1.
With the additional! information provided pursuant to paragraph 3 below, it appears that the lettering system adopted by Licensee and used by the parties to date is capable of permitting an adequate evidentiary hearing on the issues in thia proceeding and sh,ould be retained and used throughout this proceeding, including any appeals, except that the stipulation shall not pertain tc the identity of any individual who has voluntarily agreed or hereafter agrees to make his/her identity known in this proceeding.
2.
A Protective Order should be issued requiring non-disclosure of any name of any person who is identified by letter rather than by name, should that person's name be disclosed during this proceeding,
including any appeals.
3.
Subject to the Prctective Order referred to in paragraph 2 above, Licensee shall provide to the Special 8111180319 811113 PDR ADOCK 05000289 iA POR.
r sas ter, counsel for the NRC. staff, counsel for the Co==onwealth, Mrs. Aamodt and counsel for the Aamodts and
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the two undersigned representatives of TMIA, a key which identifies by name and job title all Licensee employees and ex-employees (excepting "YY") which heretofore have been designated by letter or number.
This key shall be provided exclusively for use by participants in this captioned proceeding before the Special Fbster and appeals therefrom.
The key provided shall be retained by the undersigned representatives and counsel for their use and the use of those assisting them in the course of this proceeding.
In order to assure the effectiveness of this stipulation, no copies of the keys shall be made and their use by th.ose other than the undersigned shall be restricted to the absolute minimum necessary for hearing preparation and for subsequent appeals.
Licensee further agrees to' drop the lettering sys tem throughout the proceeding for all employees other than its past and present control room' operators, shif t foremen, shif t supervisors, shif t technical advisors, and individual. "VV" and
'with respect to these individuals, each individual's
, job classification will be identified.
Licensee further agrees to review all documents it has provided in the course of discovery and to provide as soon as possible to all participants in the proceedings, subject to the Protective Order referred to in paragraph 2 above, material (other than names and job classifications) which has been deleted, such as dates, in furtherance of the lettering system.
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4.
If those parcons identified in the Li~censee's lettering system as "0", "VV" and "W" (and such t.tet persons as may be subsequently determined by the Special Master to merit an h camera preceeding-for their testimony) are called to testify in this reopened proceeding, their testimony will be taken M camera, without public notice,,
and at a place to be agreed on by the parties and the Special Master, so as to minimize risk of disclosure of their identities.
5.
When in_ camera session's of this proceeding are scheduled, the parties shall not disclose the fact, time and place of such sessions to anyone, before or during the session.
6.
Such in_ camera sessions will be conducted-t before Special Master Milho111n.
7.
The testimony in the h camera sessions would continue the use of the lettered system and the transcripts of in_ camera sessions 'ould be made available to the public without res triction.
8.
Should the name of any person who is identified by letter or by number in the Licensee's lettering system be disclosed during testimony of any witness, that person's name will be excised from the record and will not be disclosed by any party or the NRC staff.
9.
The NRC staff or any of its employees or subordinate bodies will not' disclose the name of any person 3
a identified by letter in the Licensee's lettering system in use id this proceeding without the consent of that person.
1.0.
The individuals' designated as "0", "W" and "W" hereby waive any objections previously stated in this proceeding to further tt imony in this proceeding by each of them, subject to the other provisions of this stipulation.
The involved individuals and the Licensee agree that they will withdraw their appeal of the Licensing Board's November 6, 1981 decis, ion, except for those portions of the opinion characterizing conduct of counsel.
Respectfully submitted,
$ Asb$k W 9M-luchael F. McBride LeBOEUF, LAMB, LEIBY, & MacRAE 1333 New Hampshire Ave., N.W.
Suite 1100
. Washington, D.C. 20036 (202) 457-7500
' Attorney for Two of Three Involved Individuals s
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J David E. Cole SMITH & SMITH, P.C.
Riverside Law Center 2931 North Front Street PA.
17110 Harrisburg,506 (717) 232-0 Attorney for One of Three Involved Individuals 4
SHAW, PITTMAN, POTTS &
TROWBRIDGE 4
By Q We WA uk, Partner 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Attorneys for Metropolitan Edison Company N //V r.-
Lucinda Low Swartz Office of the Executive Lega Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 (301) 492-7519 Counsel for the liRC Staff Lw / ~l~
, y Joanne Doroshow
/etc}w t hA c
Louise Bradford TMI Alert, Inc.
314 Pfeffer Street Harrisburg, PA 17102 (717) 232-3070
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7 ohn W Clewett The Christic Institute 1324 North Capitol Street Washington, D.C.
(202) 797-8106 Counsel for the Aamodt Family 7
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.a Mrs. Marjorie M. Aamodt t
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CN Robert W. Adler Assistant Counsel 505 Executive House P.O. Box 2357 Harrisburg, PA 17120 (717) 787-7060 Attorney for the Con =tonwealth of Pennsylvania Approved:
Date Approved:
huf f h frv./Q/9W 7-v Gary L. Milhollin Ad:ninistrative Judge and Special Master C
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