ML20093D601
| ML20093D601 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/09/1984 |
| From: | Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| CON-#484-342 CL-84-18, SP, NUDOCS 8410110306 | |
| Download: ML20093D601 (22) | |
Text
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- U-r RELATE.1CCR' 3pcNDENCE DOCK TED U31 C
[!,0.17 s 4 Oc o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of-
)
)
/
-METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart Remand o (Three Mile Island Nuclear
)
Management)
Station, Unit No. 1)
)
LICENSEE'S ANSWERS TO INTERVENOR THREE MILE ISLAND ALERT'S FOURTH SET OF INTERROGATORIES TO GENERAL PUBLIC UTILITIES Licensee, GPU Nuclear Corporation, pursuant to 10 C.F.R.
se5 tion 2.740b, hereby submits the following answers to " Inter-venor'Three Mile Island Alert's Fourth Set of Interrogatories
^
to General Public Utilities."
I '.
GENERAL OBJECTIONS I
1.
The-Licensing Board has ruled that knowledge of plant conditions other than those related to the generati.on and sub-sequent combustion of hydrogen, pressure spike and initiation of containment spray, possessed by persons other than Mr. Dieckamp, is not relevant to the Mailgram issue (Memorandum 8410110306 841009 gDRADOCK 05000289 PDR 13o8
3 l
m and~ Order Ruling on First GPU - TMIA Discovery Dispute, August 31, 1984, Pages 3-4).
On the basis of this ruling,
. Licensee. objects to-those interrogatories or portions of inter-rogatories which seek such irrelevant information, particularly knowledge of persons other than Mr. Dieckamp of incore thermocouple indications.
In addition, because the interroga-tories are not only irrelevant out also extremely onerous in inquiring into virtually every conversation and action of a host of individuals,-Licensee also objects to these interroga-tories as oppressive, unduly burdensome and expensive.
Licensee has also limited its responses to interrogatories not objected to in total to include only matters relating to generation and subsequent combustion of hydrogen, pressure spike and the' initiation of containment spray.
Such limitation of a response is noted in the response by reference to this
. General Objection.
2.
Much of the information sought by TMIA in these in-
- terrogatories has previously'been obtained by Licensee and placed in the Discovery Room in the form of questionnaires issued by Licensee to many of atu employees and others.
Where reference to the questionnaires will answer an interrogatory,
-Licensee has so.noted in its response and had not reiterated the information contained in the questionnaires.
To the extent j
such interrogatory would otherwise require, Licensee objects to i
it as oppressive, unduly burdensome and expensive. tn L
L
c 3.
The Licensing Board's limitation of discovery set out
.in its August 31, 1984 Memorandum and Order, supra, applied by its terms only to interrogatories-and document requests.
In-quiry into a deposition witness' knowledge of plant conditions
'is not_ limited insofar as it pertains to communications with Mr. Dieckamp.
Many.of the persons to whom TMIA's Fourth Set of Interrogatories have been specifically directed have been de-posed or.have been noticed for deposition, thereby affording TMIA the opportunity, of which it is taking full advantage, to make such inquiries as it chooses into the same subjects as are now the subject of these interrogatories.
Where such is the
' case, Licensee has so noted in its responce and has not pro-vided an interrogatory response.
To require Licensee to re-spend to the same questions again would be oppressive, unduly Lburdensome, and expensive.
II.
INTERROGATORIES Interrogatory 1.
The following interrogatories refer to ti.e " Moore notes",
which were attached to the September 17, 1980 Memorandum from Mr. Wallace to Mr. Arnold.
(a)
Explain the circumstances under which Mr. Moore took all notes which appear as an attachment to the Arnold mem-orandum.
Include in your explanation identification of the following:
(i) the purpose for his taking each portion of the notes; (ii)
Mr. Moore's location at the time he took each portion of the notes, including a description of which portions of the notes were taken at each place;
m'
-i (iii)' the persons to whom,.on' March 28, 1979, Mr.- Moore communicated'the information contained in his notes land.the purpose-for which he. communicated that information to each such person.-
This subpart should be answered with regard lto:each portion of the notes, subdivided by time of notation, so:that it is clearly understood what? portion of the notes _or the'information contained in-the notes were transfered to each person;-
-(iv) the action, if any, that any such person to whom.the.information was communicated, took on March 28, 1979
-after receiving-such information, insofar as it related to ac-tions related.to TMI-2 reactor or the ongoing accident; (v)
The time, purpose, and location at which Mr._ Moore transmitted.the information in his notes, specifical-
.ly the information that in-core thermocouple temperatures had exceeded 2500. degrees, to Mr.' Arnold, Mr. Wallace, or lMr.-Dieckamp, if any of these three individuals were identified
.in.:: response to subpart (iii) above; (vi)- whether on March 28 or_up to 12:00 p.m. on
' March 29, _1979, the information-that in-core thermocouple tem-peratures'had exceeded.2500 degrees led to any discussion about the possible generation of hydrogen or the possibility of seri-ous core damage; (vii) ;whether or not any conclusion w~as reached on' March 28 up until.12:00 p.m.
sn March 29, 1979, as to wheth-er or'not'in-core' thermocouple temperatures in excess of 2500 degrees indicated hydrogen generation or serious core damage; (viii) if the answer to subpart (vii) is affirma-tive, whether or not any such conclusion was communicated to licensee GPU upper management, the NRC, or the Commonwealth of Pennsylvania authorities.
Response 1.
General Objection:1.
General Objection 3 is also applica-
- ble in that Jim Moore has been deposed by TMIA in these areas.
)
Interrogatory 2.
State whether any of the following individuals were aware on March 28, 1979 of in-core thermocouple temperatures at TMI-2 in excess of 2200 degress on that date:
(a)
Robert Arnold; (b)
'E.G.
Wallace; (c)
Ron Williams; (d)
Robert-Keaton; (e)- William Hirtz; (f)
Rich or Richard Lentz; (g)
T.G.
(Gary) Broughton.
Response 2.
General Objection 1.
' General Objection 3 is also applica-ble in that Robert Arnold,' Richarc Lentz and T. Gary Broughton have been deposed or noticed for deposition by TMIA.
Interrogatory 3.
Describe the activities of the fo.?. lowing individuals on March 28, 1979, including identificaticn of the follbwing:
(a) the location of the indiridual at all points during the day; (b) all communications the individual had at any time during the day, with licensee personnel, the NRC, or Com-monwealth of Pennsylvania authorities; (c) all information each individual possessed on March 28, 1979 concerning.the following accident conditions or
-events:
the possible generation or combusion of hydrogen, the actuation of containment sprays, any direction not to activate equipment in order not to create a spark or combusion of noncondensible' gas; in-core thermocouple temperatures which in-dicated temperatures greater than 2200 degrees; (d) conclusions or evaluations reached as a result of any information-any individual possessed concerning any of the above-listed conditions of the reactor on March 28, 1979; n
(e) all actions taken by any GPU personnel as a re-sult of or in response to any conclusion or evaluation identi-fled in subpart (d)-above, and the person taking each such ac-tion; the time and date of taking each such action; and the purpose or reason for taking each such action;
~ (f) with respect to each action identified in re-sponse'to subpart (e) above, identify each person who is aware that such action was taken in response to any conclusion iden-tified in response to subpart (d) above; These interrogatories-are to be answered with respect to the following individuals:
(a)
Robert Arnold; (b)
Herman Dieckamp; (c)
E.G. Wallace; (d)
Ron Williams; (e)
William Hirts; (f)
Rich or Richard Lentz;
-(g)
T.G.
(Gary) Broughton;
- (h)
D.K. Croneberger; (i)
Mr. Capodanno; (j)
Mr. Lehman; (k)
Mr. Noonan.
Response 3.
3.(a) Licensee requested each individual to respond to this interrogatory.
Their responses are as follows:
(a)
Robert Arnold - was at GPU Service offices in Mountain Lakes, N. J. until about 8:00 p.m.,
at which time he returned home. L r
(b)- Herman-Dieckamp - see Licensee's response.to TMIAta First Set of Interrogatories, number 16.
L (c)
E.G. Wallace - was at a seminar.at the Hearth-stone Inn in Parsippany, N. J. until 12 noon.
At 12 noon he went to.GPU Service offices in Mountain. Lakes, M.
J. and stayed
'there until 9:30 p.m.,
at which time he returned to his resi-dance.
(d)
Ron. Williams - was at Oyster Creek Station, a
Lacey Township,-N.
J.,
and returned to his residence in the evening.
(e)
William Hirst - was in San Diego, California all
-day.
(f)
Richard Lentz - was at GPU Service offices in
- Mountain Lakes, N. J. until about 11 a.m. at which time he went home.
He left for TMI about 12 noon, arriving at thb TMI Ob-servation Center between 3 p.m.
and 4 p.m.,
and remained there until about 6 p.m., at which' time he proceeded to the TMI-2 Control Room.
He remained in the TMI-2. Control Room for sever-al hours and then returned to the TMI observation Center where he remained through the remainder of the day.
l (g)
T.G.
(Gary) Broughton - arrived at GPU Service offices in Mountain Lakes, N. J. about 8 a.m.
He went home about 11 a.m. and left for TMI about noon, arriving at the TMI 1 I
I
Observation Center between 5 p.m..and 6 p.m.
Shortly thereaf-
'ter'he left for' dinner and returned later, leaving the Observa-tion Center for the day at about 9 p.m.
(h)
D.K. Croneberger - was at the GPU Service of-fices in Mountain Lakes,.N.
J.
from approximately 8 a.m.
to 7 p.m.
He spent the remainder of the day at his residence.
(1). Mr. Capodanno - was at GPU Service offices in
-Mountain Lakes, N. J. until sometime late in the afternoon, at which time he left for the Newark, N. J.
airport for a flight to Chicago,. Illinois.
(j)
Mr. Lehmann - was at GPU Service offices in Mountain Lakes, N. J. until about 12 noon at which time he left for Three Mile Island, arriving there about 4 p.m.
For the re-mainder of the day he was at the TMI Observation Center.
(k)
Mr. Moore - was at the GPU Service offices in
. Mountain Lakes, N.
J. until shortly after the conclusion of a
-meeting that commenced at 10:05 a.m.
He left that office building for.Three Mile Island prior to noon, arriving at the North Gate of Three Mile Island about 2 p.m.,
but did not gain access.
He then proceeded to the TMI Observation Center where he remained throttghout the remainder of the day.
3.(b)-(f) General Objection 1.
General Objection 3 is also applicable in that Messrs. Arnold, Dieckamp, Lentz, t
l
_.f Broughton and Moore have been deposed or have been noticed for deposition by TMIA.
-Information requested is available in the questionnaire. responses of Messrs. Arnold, Dieckamp, Wallace,
.Lentz, Broughton, Croneberger, Lehmann and Moore.
Mr. Williams'. questionnaire was returned unopened.
Licensee
.obtainedLa new address for Mr. Williams (11 Cottonwood Road, Morristowh, N. J.
07960) and has placed the questionnaire in the mail to him.
Additionally, L_icensee has sent question-naires to Messrs. Hirst and Capodanno.
Upon receipt of Messrs.
Hirst's, Capodanno's and Williams' questionnaire respones, copi 39 will be placed in the Discovery Room.
Interrogatory 4.
Identify all conversations on March 28, 1979, between per-sons at the TMI site and licensee's offices in Parsippany con-cerning the-conditions of the reactor or events occurring at the reactor site in which the following individuals partici-pated, or of which the following individuals were aware:
(a)
Robert Arno}d; (b)
E.W. Wallace; (c)
Robert Keaton; (d)
James Moore; (e)
Ron Williams; (f)
Bill Hirts.
Include in your response identification of the following
. telephone conversations identified by Mr. Wallace in his depo-sition during the GPU v.-B&W litigation:
(a) a conversation with Leland Rogers during the af-tornoon of March 28; (b) a conversation with an individual located at the Observation Center; -
r (c) a conversation with an individual located in s' -
Harrisburg at-4:00 or 5:00 p.m.,
during which a recommendation was discussed to' start a reactor coolant pump.
Mr. Wallace states he does not remember if the call was made to the Control Room, the Shift Supervisor's Office, or the Observation Cen-ter.)
Response 4.
General Objection 1.
The information requested is contained in completed questionnaires, available in the Discov-ery Room.
Licensee, upon receipt of completed questionnaires L
of Messrs. Williams and Hirst, will place copies in the Discov-ery Room.
General Objection 3 is also applicable in that R. C.
s Arnold and J.
P. Moore have been deposed by TMIA.
None of the telephone conversations identified by Mr. Wallace in his deposition during the GPU vs. B&W litigation
-concerned or were related to hydrogen generation and subsequent combustion, actuation of containment spray or the pressure
-spike.
Interrogatory 5.
What are the duties and. responsibilities of each of the following persons called into Mr. Arnold's office in the early afternoon of March 28, 1979, to discuss the TMI accident and the conditions of the reactor, referenced in Mr. Wallace's B&W Deposition:
(a)
James Moore; (b)
E. Wallace; (c)
Ron Williams; (d)
Robert Keaton; (e)
Bill Hirts. x
.r
Response 5.
4 Licensee requested each individual to respond to this interrogatory.
Their responses follow:
(a)
James Moore - was not present in Mr. Arnold's office in the early afternoon on March 28, 1979; (b)
E. Wallace - with respect to that meeting he had no specific duties or responsibilities; (c)
Ron Williams - was not present in Mr. Arnold's office in the early afternoon on March 28, 1979; (d)
Robert Keaten - with respect to that meeting he had no specific duties or responsibilities; (e)
Bill Hirst - was not present in Mr. Arnold's of-fice in the early afternoon on March 28, 1979.
Interrogatory 6.
Identify all persons who were routinely located at Parsipanny, N.J.,
who were permitted access or entrance to the TMI-2 Control Room at any time during March 28, 1979, and all persons who granted any persons identified above that authority and/or permission to enter the TMI-2 control room; Identify the purpose or reason each such person identified above was permitted access to the TMI-2 control room at that time.
Response 6.
General objection 1.
Richard Lentz was the only person rountinely located at GPU Service offices in New Jersey who went into the TMI-2 Control Room at any time during March 28, - - -
1979.
According to-Mr.'Lentz, his access was granted by George Kunder for the purpose of obtaining copies of plant data.
Interrogatory 7.
Identify all documents which record or memorialize each communication and conversation. identified in Interrogatory Nos. 3 and 4 above.
Response 7.
General Objection 1.
The information requested is contained in completed questionnaires, available in the Discov-ery-Room, except for Messrs. Capodanno, Hirst and Williams.
Licensee, upon receipt of their completed questionnaires, will place copies in the Discovery Room.
Interrogatory"8.
Identify with respect to the following individuals whether or not they viere aware on March 28, 1979 that the occurrence of cladding temperatures in excess of 2200 degrees F. exceeded those specified in 10 CFR 50.46:
(a)
Gary Miller; (b)
George Kunder; (c)
Ivan Porter;
_(d)
Michael Ross; (e)
Theodore Illjes; (f)
William Zewe; (g)
Edward Frederick; (h)
Craig Faust; (i)
Joseph Chwastyk; (j)
Brian Mehler; (k)
Robert Arnold; >
a m-
73 3
.w V
s
[ i ;-
p T
(1))' James Moo ~e; fm). E.. 'Wallace;.
(n)
Robert Keaton; (o). J.G.lHerbein.
Response 8.
' General-Objection 1.
General Objection 3 is also applica-bleLin thatlGary Miller, George-Kunder, Theodore Illjes, Craig Faust,~ Joseph Chwastyk, Robert Arnold, James Moore, Brian Mehler,.-Ivan' Porter, Michael'Ross, and J. G.~Herbein have been
. deposed by TMIA._
Interrogatory 9.
i Identify which if any of the persons listed in Interroga-tory No. 8 above were aware on March 28,.1979, or March 29, 1979, that in-core' temperatures in excess of 2200 degrees F hed
-been measured?
With regard to any individual identified above, state the-a time at which he so' learned of the temperatures and the. indica-tor from which he learned.of the: temperatures, i.e. computer printout, digital-voltmeter (nr fluke thermometer.
Response 9.
General Objection 1.
General objection _3 is also applica-
.ble; see response to interrogatory 8.
Interrogatory 10.
Identify all persons listed in response to Interrogatory No. 9Labove, who did not believe the accuracy or validity of the. temperatures, and the reason (s) for such disbelief.
Response 10.
General Objection 1.
General objection 3 is also applica-
[
'ble;_ see response to interrogatory 8.
4.
- -. _. _ _ _ -. _. - - - - - - - - - _ _ - - -.. - - - - _ - -.. _ - _ - - _ - _ -.. - - - -.. ~.. - - _ - _ _ - _ _ _ - - - - - - - - - _. _ _ _ _ _ _ _ - _ _, - _. - - _. - - - - _ _ _ _ -. _ _ _
-. a
m.
L l'
E Interrogatory 11.
4 v.
Identify all communications on March 28, 1979, among GPU
. personnel, or-between GPU.and B&W personnel, concerning the fact.that:in-core thermocouple readings of temperatures in ex-cess of 2200 degrees F had been measured on March 28, 1979.
Response 11.
General Objection 1.
General Objection 3 is also applica-ble; see response to interrogatory 8.
~ Interrogatory 12.
Identify all. communications, discussions, conversations, or other contracts among GPU personnel, or between GPU and B&W
-personnel, related to whether in-core thermocouple readings of i
temperatures in excess of 2200 degrees F indicated that hydro-gen had been generated.
o, Rhsponse 12.
-General Objection 1.
General Objection 3 is also applica-ble; see response to interrogatory 8.
Interrogatory 13.
l LIdentify all communications, discussions, conversations, or other contacts among GPU personnel, or between GEU and B&W
. personnel, related to whether in-core thermocouple readings of temperatures in excess of 2200 degrees F indicated that the core had been damaged.
Response 13.
General Objection 1.
General Objection 3 is also applica-ble; see. response to interrogatory 8.
Interrogatory 14.
Describe any electrical malfunction of any kind which would appear on a wide-range or narrow-range pressure recorder of the same shape, wave length or character as the pressure spike which was recorded on a wide-range and narrow-range re-corder at approximately 1:50 p.m. on March 28, 1979 at TMI-2. '
4
^
- p
-s>
x Response-14.
In order forfLicensee to respond to this interrogatory-it 2
would be necessary for Licensee to create "as built" plant de-sign conditions at TMI-2.
This would be oppressive, burdensome.
Land'conceiv' ably-impossible due to the present condition of TMI-2. :Thus, an in-depth and adequate analysis to determine whether any electrical malfunction of any kind would appear on a wide-range or narrow-range pressure recorder of the same-shape, wave length or character as.the pressure spike which was recorded on a wide-range and narrow-range recorder at approxi-mately 1:50 p.m. on March 28, 1979 at TMI-2 would involve a tremendous undertaking by Licensee.
Licensee therefore objects to this interrogatory.
Interrogatory 15.
Describe any electrical malfunction of any kind which could lead to the reactor building chart recordings of the pressure spike and the initiation of~ containment sprays which occurred almost simultaneously on March 28, 1979 at or about
.1:50 p.m.
Response 15.
In order for Licensee to respond to this interrogatory it would be necessary for Licensee to recreate "as built" plant design conditions at TMI-2.
This would be oppressive, burden -
some and coaceivably impossible due to the present condition of TMI-2.
Thus, an in-depth and adequate analysis to determine p
whether any electrical malfunction of any kind could lead to the reactor building chart recordings of the pressure spike and. - -
a
.the~ initiation of~ containment spray which occurred almost si-multaneously on March 28, 1979 at or about 1:50 p.m. would in-volve a tremendous undertaking by Licensee.
Licensee therefore
. objects.to this interrogatory.
Interrogatory 16.
Identify all actions, including any communications, inqui-ries, investigations or other efforts, Mr. Dieckamp took prior to May 9, 1979, to determine whether any licensee or B&W per-sonnel interpreted the pressure spike on March 28, 1979, to in-dicate core damage.
Response 16.
Prior to May 9, 1979, Mr. Dieckamp undertook no special inquiries, investigations, communications or other efforts to determine whether any licensee or B & W personnel interpreted the pressure spike on March 28, 1979, to indicate core damage.
The basis for the statements in the Mailgram are outlined in Licensee's'respone to TMIA's First Set of Interrogatories, num-bers 54, 55, 56 and 58.
Interrogatory 17.
Identify all actions, including any communications, inqui-ries, investigations or other efforts Mr. Dieckamp took prior to May 9, 1979, to determine whether any licensee or B&W per-sonnel' interpreted initiation of containment sprays on March 28, 1979 to indicate core damage.
Response 17.
Prior to May 9, 1979, Mr. Dieckamp undertook no special inquiries, investigations, communications or other efforts to determine whether any licensee or B & W personnel interpreted initiation of containment spray on March 28, 1979 to indicate !
6 core damage.
The basis for the statements in the Mailgram are outlined in Licensee's response to TMIA's First Set of Inter-rogatories numbers 54, 55, 56 and 58.
Interrogatory 18.
Identify'all actions, including any communications, inqui-ries, investigations or other efforts Mr. Dieckamp took prior to May 9,-
1979, to determine that no one had withheld any information about the pressure spike, the initiation of con-tainment sprays, or reactor core damage.
Response 18.
Prior to May 9, 1979, Mr. Dieckamp undertook no special inquiries, investigations, communications, or other efforts to determine that no one had withheld any information about the pressure spike, the initiation of containment spray, or reactor core damage.
The basis for the statements in the Mailgram are outlined in Licensee's response to TMIA's First Set of Inter-rogatories, numbers 54, 55, 56 and 58.
Interrogatory 19.
Identify all actions, including any communications, inqui-ries,. investigations or other efforts, Mr. Dieckamp took prior to May 9, 1979 to determine'whether any GPU or B&W personnel believed on March 28, 1979b that the pressure pulse which was recorded indicated a real increase in pressure, or indicated the generation and/or combustion of hydrogen.
Response 19.
Prior to May 9, 1979, Mr. Dieckamp undertook no special inquiries, investigations, communications or other efforts to determine whether any GPU or B&W personnel believed on March 28, 1979, that the pressure pulse which was recorded
.y'
-indicated a real increase in. pressure, or indicated the genera-
. tion;and/or combustion of hydrogen.
The basis for the state-ments in the-Mailgram are. outlined in Licensee's response for TMIA's First Set of Interrogatories, numbers 54, 55, 56 and 58.
Interrogatory 20.
Identify all data which Mr. Lentz collected in the TMI-2 control room on March 28, 1979.
Identify all information which Mr. Lenz-subsequently communicated to licensee personnel in the
' Observation Center / Visitors' Center on March 28, 1979, and the reason or purpose for communicating such information.
Specifi-cally address whether Mr. Lentz communicated any of the infor-mation he collected to the following persons:
(a)
James Moore; (b)
E. Wallace; (c)
Robert Arnold; (d)
Robert Keaton.
State whether or not any person identified above trans-mitted any of this information to Mr. Dieckamp.
Response 20.
General Objection 1.
Today, Mr. Lentz recalls baking copies of pages from the computer alarm printer and other plant data.
The information copied, to his recollection, was for the period shortly before 0400 and for several hours thereafter.
Mr. Lentz states that he did not have any knowledge on March 28, 1979 of the pressure spike, containment spray
- actuation or generation and subsequent combustion of hydrogen at about 1350 on March 28, 1979, and, therefore, did not commu-nicate any information relative thereto to Messrs. Moore, Wallace, Arnold or Keaten on that day.
These four individuals.
O
A likewise recall.no such discussion or other communications with
'Mr.:Lentz on March 28, 1979.
Mr. Dieckamp is not aware that Mr. Lentz was the source of
'any-information.which he received on March 28, 1979.
'knterrogatory21.
^
Identify all documents which recorded or memorialized the information which Mr. Lentz collected, including any data of records from-the TMI-2 Control Room which he photocopied on March 28, 1979.
Response 21.
Data collected by Richard Lentz on March 28, 1979 was used by T. Gary Broughton on that day in preparing two graphs.
The graphs are not titled, but will be made available in the Dis-covery Room in a folder identified under this interrogatory.
Interrogatory 22.
Identify the position and all duties and responsibilities of Richard'Bensel on March 28, 1979.
Identify all activities
~ including any reporting activities of Mr. Bense1~on March 28, 1979, concerning the TMI-2 accident.
Response 22.
General objection 3 is applicable in that Richard Bensel has been deposed by TMIA.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Tew+-f, M A.
Ernest L. Blake, Jr.,
P.C.
Counsel for Licensee Dated: october'9, 1984.
F...
October 9, 1984 I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart Romand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE r
I hereby certify that copies of " Licensee's Answers to In-tervenor Three Mile Island Alert's Fourth Set of Interrogato-rios to General Public Utilities," dated October 9, 1984, were served upon those persons on the attached Service List by de-posit in the United States mail, postage prepaid, this 9th day of October, 1984.
j f hoY.
Ernest L. Blake, Jr., P.C.
Dated: October 9, 1984 i
L l
c--
r UNITED STATES OF AMERICA NUCLEAR REGULATORY C049tI3SION BEFORE THE ATOMIC SAFETY AND LICENSING 50ARD f
In the Matter
)
)
METRDFOLITAN EDISCW COMPANY
)
Docket No. 50-209 SP
)
(Restart Romand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Conunission Jonn H. Buck Washington, D.C.
2055$
Atomic Safety & Licensing Appeal Board Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commiss;;
U.S. Nuclear Regulatory Commission Washington, D.C.
2055$
Washington, D.C.
20555 Administrative Judge
-James K. Asselstine, Commissioner Christine N. Mohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Corraissac Frederick Bernthal, commissioner Washington, D.C..
20555
'U.S. Nuclear Regulatory Conusission Washington, D.C.
20555 Administrative Judge Ivan W. Smith, Chairman Lando W. Seek, Jr., Commissioner Atomic Safety & Licensing Soard U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Cornissa::
Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Gary.J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licer. sing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear - Regulatory Commiss L::
U.S. Nuclear Regulatory Conusission Washington, D.C.
2055$
Washington, D.C.
20555 h
O O
1 o
Administrative Judge Nr. Henry D. Mukill Gustave A. Linenberger, Jr.
Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 4WO Washington, D.C.
20555 Middletown, PA 17057 Docketing and service Section (3)
Mr. and Mrs. Norman Aamodt Office of the secretary R.D. 5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C.
20555 Ms. Louise Bradford Atomic 3afety & Licensing Board TMI ALERT Panel 1011 Green street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C.
20555 Joanne Coroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute l
Board Pane;.
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) 00{*
^
""* *ili Y office of the Executive Legal r
c 1555 Connecticut Avenue U.s c ear Regulatory Commission Washington, D.C. 20036 Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Harmon, Weiss 6 Jordan Thomas Y. Au, Esq.
2001 S Strast, U.W., Sutte 431 Office of C.tief Counsel Washington, D.C.
20009 Department of Environmental Resources Michael F. McBride, Esq.
505 Executive House LeSceuf, 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.
of Human Factors Safety Hunton & Williams of fice of NRR 707 East Main Street Mail Stop AR$200 P.O. Box 1535 U.S. Nuclear Regulatory Richmond, VA 23212 Commission Washington, D.C.
20555
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