ML20093D311

Third Supplemental Response to TMI Alert First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20093D311
Person / Time
Site:	Three Mile Island
Issue date:	10/09/1984
From:	Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	THREE MILE ISLAND ALERT
References
CON-#484-341 SP, NUDOCS 8410110199
Download: ML20093D311 (10)

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i October 9, 1984 RELATED CORRES?CNDF.NCQ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0 BCT10 mg;,g Before the Atomic Safety and Licensing Boa d ((f '; {Tu v f

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In the Matter of )

METROPOLITAN EDISON COMPANY ) Docket No. 50-289)

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-(Three Mile Island Nuclear ) on Management)

Station, Unit No. 1) )

LICENSEE'S THIRD SUPPLEMENTAL RESPONSE TO THREE MILE ISLAND ALERT'S FIRST SET OF INTERROGATORIES In accordance with Licensee's agreement with Three Mile Island Alert (TMIA), as memorialized in letter from. Ernest L.

Blake.to Lynne Bernabei, dated September 24, 1984, Licensee provides the following supplemental response to TMIA's First Set of Interrogatories.

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Supplemental Response to Interrogatory No. 2 j On March 28, 1979, at approximately 8:00 a.m., an open i

line was established between the NRC Region I Incident Response

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Center and the TMI-2 Control Room. Shortly after 10:00 a.m.,

this line of communication was transferred to the Unit 1 con-trol room. -A tie-in between this line and NRC Headquarters in i

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Bethesda was established at about 12:30. At about 4:30 p.m.

this first line was changed back to a two-way line between Re-gion I and Unit 1, and a new three-way line was established be-tween Unit 2, NRC Headquarters, and NRC Region I. These lines of communications were continued on the 29th. Licensee does

'not know when they ceased.

Licensee is aware of no dedicated or open lines between Licensee in Parcippany and the NRC on March 28, 1979.

-These lines of communications are discussed extensively in NUREG/CR-1250, "Three Mile Island: A Report to the Commission-ers and to the Public," Volume II, Part 3, pp. 871-72, 944-968, 1040, and 1121-1126 (January 1980).

Supplemental Response to Interrogatory No. 4 Licensee has no knowledge of an open or dedicated line being established on March 28, 1979, between B&W in Lynchburg and the NRC in Bethesda.

Supplemental Response to Interrogatory No. 5 An open line was established with TMI-2 and the Pennsylvania Bureau of Radiation Protection in Harrisburg at 7:25 on March 28, 1979. This line was kept open for about the next two weeks. Licensee does not know exactly when it ceased.

See NUREG/CR-1250, at pp. 871-72, 1040, and 1194-95.

Supplemental Response to Interrogatory No. 6 A direct line from the Unit 2 control room to B&W in Lynchburg was established at 6:30 p.m. c. March 28, 1979. Li-censee does not know when this line of communication ceased.

See NUREG/CR-1250, at 887.

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Supplemental Response to Interrogatory No. 12 The following information refers to'the alarms described

- on the alarm printout that was produced in response to this in-terrogatory. The alarms numbered below-(in the third column on the printout) which do not have " NORM" printed in the fifth column-trigger a flashing light on the annunciator panel and an alarm' horn. Many.of these alarms appear more than once.

Pressing the_ acknowledge button stops the flashing light and.

horn for all alarms that have come in up to that time. Elimi-nation of the alarm condition before the acknowledge button is pressed (momentary alarms) does not turn off horn or flashing light. The alarms numbered below which have " NORM" printed in the fifth column do not trigger the light or the horn but are automatically. printed.

2818 through 2820 3050 2827 through 2830 3167 through 3170 2832 through 2839 3264 through 3265 2843 through 2845 3278 through 3281 2852 through 2854 -

Alarms not listed.above and that have only words or let-ters printed in the fifth_ column do not trigger lights or the

-horn but are automatically printed out on the computer printer.

When the printer types these alarms.a bell sounds on the print-er except those alarms where " NORM" is printed in the fifth column.- The bell does not sound for the alarms where " NORM" is printed.

Alarms not listed above-that have numbers or quest. ion marks printed out in the fifth column are printed in response

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,6-w to operator requests and do not trigger the bell on the print-er.

For all alarms where the.same alarm is reported through more than one channel, e.g. 3167,-3168 and 3169 or 3278, 3279 and'3280, only one light is triggered on the annunciator panel.

Supplemental Response to Interrogatory No. 15 Mr. Arnold has no recollection of any conversations during the May 7, 1979 Ccngressional visit to TMI-2; he is uncertain if~he. accompanied the Congressional party on the plant tour.

Mr. Herbein believes that at the end of the tour Congressman Udall-gave a statement'to the press concerning the spike, but Mr. Herbein cannot recall what was said. Mr. Herbein is also uncertain whether he accompanied the Congressional party on the plant tour.

-Licensee has been unable to identify the GPU personnel, other than those persons previously identified, who attended the Congressional visit. Licensee has, however, identified four GPU employees who may have been on duty in the control room-at the time of the tour. They are T. Illjes, B. Conaway, C. Mell, and.J. Kidwell.

Supplemental Response to Interrogatory Nos. 16 and 34 Messrs. Miller, Herbein and Kunder recall talking briefly to Mr. Dieckamp prior to their March 28, 1979 meeting-with the Lt. Governor. They have already been deposed by TMIA on the specifics of the conversation.

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~b Mr. Arnold has also been deposed by TMIA on subject of these interrogatories.

Mr. Keaten believes that he talked to Mr. Dieckamp on March 30, 1979, and believes that he related to Mr. Dieckamp information' received from telephone conversations from T. Gary Broughton, which is contained in Keaten's notes. Mr. Keaten's notes were previously made and are still available in the Dis-covery Room.

Messrs. Long, Wallace, and'Kuhns do not recall having any conversations with Mr. Dieckamp on March 28 through 30 relating to topics specified in Interrogatory No. 16; Messrs. Blake and J. Wilson had no such conversation.

Supplemental Response to Interrogatory bo. 28 On the evening of March 28, 1979, Mr. Arnold advised Mr.

Dieckamp of repressurization. Mr. Dieckamp does not recall being informed of the identity of the person who instructed Emergency Team personnel to cease the depressurization strategy and begin a repressurization strategy. Mr. Arnold does not re-call so-informing Mr. Dieckamp.

Supplemental Response to Interrogatory No. 39 Licensee addressed this interrogatory to Mr. Troffer. His response has been placed in the Discovery Room.

Supplemental Response-to Interrogatory Nos. 42-43 Licensee does not know who performed the radiation mea-surement that was logged at 2:05 p.m. on March 28, 1979. The results of this measurement were reported to Beverly Goode, who

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was the author'of the log entry. . Licensee is unaware of the

~ identity of the radio operator who received the measurement, or of any other person having been informed of the results of the 1 measurement, or of.any action being taken in response on March 28, 1979.

Supplemental Response to Interrogatory Nos. 44-47 Mr. Dieckamp can recall no conversations-that he had with GPU officers or employees relating to'an evaluation of the al- ,

leged falsity of the mailgram and/or the need for corrective

' action.

Supplemental' Response to Interrogatory No. 48 Licensee probably received the transcripts of the Mehler and Chwastyk IEE (NUREG-0600) interviews in September or early October, 1979.

Supplemental Response to Interrogatory No. 51 The distribution of interview memoranda was typically to Messrs. Ernest L. Blake and John F. Wilson.

Supplemental Response to Interrogatory Nos. 52 and 58 Current GPU system personnel who attended the GPU Board or annual meeting with Mr._Dieckamp on May 8 and 9, 1979, are as follows: . Messrs. W. Kuhns, V. Condon, E. Holcombe, D.

Baldassari, S. Bartnoff, W. Verrochi, J. Graham, J. Farrell, F.

Hafer,'F. Glickman, B. Cherry, and W. Murray. They do not re-call any conversation or consultation with Mr. Dieckamp con-cerning the N.Y. Times article, the mailgram, or Licensee's ap-preciation on March-28, 1979, of.the severity of the accident.

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.t However, the minutes of the annual meeting indicate that in re-sponse to a shareholder's criticism of the press, Mr. Dieckamp read aloud portions of his mailgram.

Response to TMIA's Additional Requests The documents to which Mr. Harbin refers in his question-naire are J. Seelinger's notes. The documents to which Mr.

-Orlandi refers are observation center logs for March 29 and March 30, 1979.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE W 7 ss-4 A.

Ernest L. Blake, Jr., P.C.

David R. Lewis Counsel for Licensee Dated: October 9, 1984

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NUCLEAR REGULATORY COMMISSION -

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CERTIFICATE OF SERVICE I hereby certify that copies of ". Licensee's Answers to In-tervenor Three Mile Island Alert's Fourth. Set of Interrogato-

$ i ries to, Gene $ra 1 Public Utilities," dated October 4 . .

9',; 1984, were I

served upon those' persons on the attached Service List by de-t posit in the United States mail, postage prepaid, this 9th day s .

q of October,,1984.

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L Ernest L. Blake, Jr., P.C.

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Nunzio J. Palladino, Chairman Administrative Judge EU.S. Nuclear Regulatory Commission John H. Buck Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board Thomas M.. Roberts, Commis'sioner U.S. Nuclear Regulatory Commissier

'U.S. Nuclear Regulatory Commission Washington, D.C. 20555 f Washington,- D.C. '20555 1 a

Administrative Judge J'ames K. Asselstine, Commissioner Christine H.-Kohl U.S. Nuclear Regulatory Commission Atomic Sefety & Licensing Appeal Washington , D. C'. 2[$55 Board t( ,.( U.S. Nuclear Regulatory Commissice

, Frederick Bernthal,\ Commissioner -s' Washington, D.C.

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-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ' Administrative Judge Ivan W. Smith, Chairman-

Lando W. Zeck, Jr.,' Commissioner 7, ~

Atomic Safety'& Licensing Board U.S.4 Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissics:

WasY.ington,.D.C. 20555 Washington, D.C. 20555

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' Administrative. Judge , Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe

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U.S. NuciparLRegulatory Commission Washington, D.C. 20555 Washington ',; D.C. 20555 A. '

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s 2-Administrative Judge Mr. Henry D. Hukill Gustave A. Linenberger, Jr. Vice President Atomic Safety & Licensing Board , GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C. 20555 Middletown, PA 17057 Docketing and Service section (3)

Office of the Secretary Mr. and Mrs. Norman Aamodt R.D. 5 U.S. Nuclear Regulatory Commission Coatssville, PA 19320 Washington , D. C. 20555 Atomic Safety & Licensing Board Ms. Louise Bradford TMI ALERT Panel 1011 Green Street U.S, Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C. 20555 Joanne Doroshow, Esquire Atomic Safety & Licansing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C. 20002 Washington, D.C. 20555 Lynne Bernabei, Esq.

Jack R. Goldberg, Esq. (4) G **r ment Accountability Office of the Executive Legal r 1555 Connecticut Avenue U.S c ear Regulatory Commission ashington, D.C. 20036 Washington, D.C. 20555 Ellyn R. Weiss, Esq.

Harmon, Weiss & Jordan Thomas Y. Au, Esq. 2001 S Street, N.W., Suite 430 Office of Chief Counsel Washington, D.C. 20009 Department of Environmental Resources Michael F. McBride, Esq.

505 Executive House LoBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.

Harrisburg, PA 17120 Suite 1100 Washington, D.C. 20036 William T. Russell Deputy Director, Division Michael W. Maupin, Esq.

I of Human Factors Safety Hunton & Williams Office of NRR' 707 East Main Street Mail Stop AR5200 P.O. Box 1535 U.S. Nuclear Regula tery Richmond, VA 23212 Commission Washington, D.C. 20555 l

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