ML20093D982

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Supplemental Response to Third Set of Interrogatories & Third Request for Production Re Dieckamp Mailgram.W/Svc List.Related Correspondence
ML20093D982
Person / Time
Site: Crane 
Issue date: 10/09/1984
From: Bernabei L, Doroshow J
CHRISTIC INSTITUTE, GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To:
GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20093D971 List:
References
SP, NUDOCS 8410110499
Download: ML20093D982 (5)


Text

l RELATED CORRESP6ql0/9/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CKETED USNRC Before the Atomic Safety and Licensing Board' 14 RU 11 M112 OFFICE JF 5 ECRL.,.

NUEIyjdyE8WO

-In~the-Matter-of

)

)

METROPOLITAN EDISION COMPANY

)

Docket No. 50-289

)

(Restart - Management

'(Three Mile Island Nuclear

)

Phase)

Station, Unit 1)

)

THREE MILE ISLAND ALERT'S SUPPLEMENTAL RESPONSE TO LICENSEE'S THIRD SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION (DIECKAMP MAILGRAM)

Interrogatory No. 19 TMIA currently intends to call as witness in this proceeding Victor Gilinsky, former Commissioner of the Nuclear Regulatory Commission ("NRC").

Dr. Gilinsky was the senior NRC commissioner at the time of-the TMI-2 Accident. He participated in the May 7, 1979 site visit by the Subcommittee on Energy and the Environment of the Committee on Interior and Insular Affairs of the House of Representatives. During this site visit he spoke to Mr.

Dieckamp about the pressure spike and reporting of the pressure spike to.the Commission. This site visit became the subject of the New York Times article of May 8, 1979, which prompted the"Dieckamp mailgram". Dr. Gilinsky also was an addressee of the Dieckamp mailgram.

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- TMIA proposes to offer Dr. Gilinsky's testimony for the following purposes:

1).. Dr. :Gilinsky's conversation 'with Mr. Dieckamp on May 7,.1979'and, in his role as Commissioner, communications with,xthe licensee'during the accident and.its aftermath,.is m

relevanti and probative' evidence concerning Mr. Dieckamp's state of mind at the. time of sending the mailgram and his purpose in sending lthe mailgram to Congressman Udall and Commissioner-Gilinsky.

2)'. Dr. Gilinsky, as an addressee of the mailgram and.from his communications :directly with Mr. Dieckamp and the licensee, can testify

-on his understanding of the relevant portions of the mailgram.

'3). Dr. Gilinsky, as the' senior commissioner at the time of the

. accident, can. testify a$ to the information the Commission relied on in making its decisions regarding.the accident, and the information the licensee was obligated to report to the Commission in order to permit the Commission to make its decisions.

Mr. Dieckamp, if he did not know at the time of s,ending

~

the mailgram that it contained inaccurate statements, should have known of'the inaccurate statements since he should have made the inquiries necessary to assure the accuracy of all infor-mation he included in the mailgram.

The Commission's expecta-tions-and regulations regarding licensee's reporting of information to the NRC, which were communicated to the licensee, are probative of Mr. Dieckamp's understanding of his obligations to report information about the pressure spike, the actuation of

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=

, containment sprays, hydrogen generation or burn,in-core thermo-couple temperature readings, and core damage, to the C6mmission.

It is also probative of-.Mr. Dieckamp's responsibilitiy-to ensure the accuracy of any information on such matters when reported to

.the Commission, Congress or the public.

Respectfully submitted, tha CLtv W oanne Doroshow he Christic Institute 1324 North Capitol Street Washington, D.C.

20002 Telephone: 202/797-8106 (Luk L

e Bernabei G ve nment Accountability Project 1"55 Connecticut Ave., N.W.

Suite 202 Washington, D.C.

20036 Telephone:

202/232-8550 Dated:

October 9, 1984 Attorneys for Three Mile Island Alert f

l

RELATED CORRESPONDENC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board C0;gErgp 1

UShAC.

-In the Matter of

)

METROPOLITAN EDISON COMPANY

)

Docket No. 50-289 SP 0011 A11:12

)

-(Three Mile Island Nuclear

)

(Restart - ManagementFPhase)::,a f_

Station, Unit No. 1)

-)

C0CMCh4GISEd>b' DRANCH I hereby certify. that a copy of the foregoing

TMIA's Second Supplemental Response to Licensee's First i

Set of Interrogatories, TMIA's Response to Licensee's Third -Set of Interrogatories,. and TMIA's Supplemental Response to Licensee's Third Set of Interrogatories, have i

been served this 9th day.of October, 1984, by mailing a_ copy.first class, postage prepaid to the'following:

SERVICE LIST i

Administrative Judge _

Thomas Office,Au, Esq.

.Ivan W.' Smith, Chairman of Chief Counsel i

. Atomic Safety & Licensing Board Department of Environmental U.S. Nuclear Regulatory Commission Resources Washington,-D.C. 20555 505 Executive House P.O. Box 2357 Administrative Judge Harrisburg, PA 17120 Sheldon-J. Wolfe Atomic _ Safety & Licensing Board John A. Levin, Esq.

U.S. Nuclear Regulatory Commission Assistant Counsel.

Washington, D.C.

20555 Pennsylvania Public Utility Commission Administrative Judge P.O. Box 3265 Gustave A. Linenberger, Jr.

Harrisburg, PA 17120 Atomic Safety & Licensing Board U.S. Nuclear Regulatory-Commission

  • Ernest L. Blake, Jr.

Washington, D.C.

20555 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Docketing.and Service Section (3)

Washington, D.C.

20036 Office of the Secretary U.S. Nuclear Regulatory Commission Mr. Henry D. Hukill Washington, D.C. 20555 Vice President GPU Nuclear Corporation Atomic Safety & Licensing Board P.O. Box 480 t

Panel Middletown, PA 17057 l

U.S. Nuclear Regulatory Commission i

Washington,-D.C. 20555 Mr. and Mrs. Norman Aamodt R.D. 5 Atomic Safety & Licensing Appeal Coatesville, PA 19320 Board Panel U.S. Naclear Regulatory Commission Ms. Louise Bradford Washington, D.C. 20555 TMI ALERT 1011 Green Street Jack R. Goldberg, Esq.

Harrisburg, PA 17102 Office of the Executive Legal i

Director Joanne-Doroshow, Esq.

U.S. Nuclear Regulatory Commission The Christic Institute i

Washington, D.C.

20555 1324 North capitol Street j

Washington, D.C.

20002

- _. _ _., _ _ _. ~. _ _ _

, Michael F. McBride, Esq.

Ellyn R. Weiss, Esq.

LeBoeuf, Lamb, Leiby & MacRae William S. Jordan, III,'Esq.

1333 New Hampshire Avenue, N.W.

Harmon, Weiss & Jordan suite 1100 2001 S Street, Northwest Washington, D.C.

20036 Suite 430 Washington, D.C.

20009 Michael W. Maupin, Esq.

Hunton & Williams 707 East Main Street Post Office Box 1535 TMI-FIRC Legal Fund 1037 Maclay Richmond, VA 23212 Harrisburg, Penn.

17103 fAW W J-%

LyfinA Bernabei 4

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  • Hand Delivered i

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