ML20093E040
| ML20093E040 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/08/1984 |
| From: | Bernabei L, Doroshow J GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Blake E SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| CON-#484-425 SP, NUDOCS 8410110519 | |
| Download: ML20093E040 (2) | |
Text
\\ <(yJ RELATED COlmE3rdNDENCE GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 DMQED Washington, D.C. 20036
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(202)232-8550 Hb-DELIVEE
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Q h ksh'i'l984 SRANCH Ernest L. Blake, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street N.W.
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Washington, D.C. 20036 Paco, a urit rf,c,,,
Dear Ernie:
As you know, the Licensing Board, in its Memorandum and Order Following Prehearing Conference of September 19, 1984, stated that the parties were encouraged to begin informal discovery on the Unit 1 and Unit 2 leak rate issues.
Pursuant to the Board's order, TMIA hereby requests that the licensee provide the following within the next week to two weeks:
(1) All documents and data reviewed, gathered or obtained by licensee's consultant Edwin Steir, by licensee, or by the engineering firm MPR in connection witt, investigations into alleged falsification of leak rate tests for both Unit 1 and Unit 2.
Please include all documents related to any internal investigation, inquiry or review conducted by licensee or its consultants into these issues, including any drafts of reports, evaluations or reviews or proposed or mandated corrective action taken by licensee in response to any such investiga-tions, inquiries or reviews.
(2) All directions or instructions given to Mr. Steir, MPR, or any other licensee manager, employee or consultant concerning any internal investigation, inquiry or review of alleged falsification of leak rate tests for Unit 1 or Unit 2.
(3) All data collected and reviewed by licensee's consultant engineering firm MPR in connection with its technical analysis of Unit 2 leak rate falsifications, both before and after March,1984. According to MPR spokespersons at a public meeting with the NRC Staff on September 20, 1984, MPR has reviewed data collected by the licensee, the Department of Justice, the NRC and Mr. Steir. This data includes but is not limited to alarm printonts; shift and daily surveillance logs; strip charts; and reactor coolant inventory balance test printouts.
Please include any grand jury materials related to the alleged fattification of leak rates for Unit 1 or Unit 2.
addition, indentify all management actions taken in response to Mr. Steir's investigation of Unit I leak rates, including any disdplinary action taken against any licensee employee.
Also identify any response licensee has made to NRC Staff criticisms of the Steir investigation 84101'10519 841008 PDR ADOCK 05000289 G
PDR Q)
l Pago 2 Blake Letter-October 8,1984 h -
expressed at the September 20, 1984, public meeting or any materials Mr.. Steir, MPR or the licensee prepared for that meeting.
Mr. Steir stated at this meeting that he and his staff, in connection with his investigation of Unit 2 leak rates, would begin interviews of licensee ana other personnel at the end of September.
TMIA believes that if its representative is permitted at attend and participate in these interviews, it would be possible to expedite the discovery process.
Many of the individuals who will be questioned have in the past been interviewed many times.
In the interest of expediting the discovery process and eliminating all unnecessary burden from the individuals to be ~ interviewed, TMIA requests that it be informed of all interviews and be permitted to participate and ask questions at the interviews.
Please inform us at your earliest possible opportunity of your willingness to comply with the above requests. Since Mr. Steir expressed his intention on September 20, 1984, of proceeding immediately with interviews, please tell us this week whether or not you will permit a TMIA representative to participate in the interviews.
Sincerely yours, I.
A.
\\t Lynne Bernabei i
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Joanne Doroshow cc: Service List
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