ML20093K962

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Second Notice of NRC Staff Depositions on 841029 in Washington,Dc Re Operator Training.Certificate of Svc Encl. Related Correspondence
ML20093K962
Person / Time
Site: Crane 
Issue date: 10/16/1984
From: Jordan W, Weiss E
HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
Shared Package
ML20093K938 List:
References
SP, NUDOCS 8410180249
Download: ML20093K962 (7)


Text

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L UCS'-~ October 16, 1984 M

. UNITED. STATES'OF-AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE. ATOMIC SAFETY AND LICENSING BOARD L

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[Intthe Matter of.

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Docket No. 50-289 METROPOLITAN. EDISON COMPANY 1

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2, UCS' -SECOND NOTICE OF DEPOSITIONS TO NRC STAFF

' Pursuant.- to ol0 C.F.R.; 5 2'. 720 (h) (2 ) (i), the' Union of Concerned Scientists hereby gives notice of its intention to take

, depositions of the.following persons:

1.

The NRC Staff psychologist referred to in the letter of October 10, 1984, from Mary E. Wagner, Esquire, to= William S. Jordan, III, Esquire.

.She should bring with her the notes. referred to'in.Ms. Wagner's letter, as well as any other in her possession or control that relate in notes any way tol reactor operators or operator training at Three Mile Island.

-2.

All persons who were involved in the preparation of the review.of the-GPU licensed Operator

Requalification and' Replacement program described at NUREG-0680, bupp.

5, p.

7-13, including those who did the reviews and evaluations and those, if different,'who-drafted the relevant sections of the written review.

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' t They should bring with them all documentation (including notes, drafts and final reports and input to reports, memoranda, interview notes, evaluations, and all other documents) of their review, including, but not limited to, the records of the six licensed operators whose records were reviewed and the notes and/or transcripts of the interviews with two licensed operators.

They should also bring with them their resumes and statement of qualifications.

3.

All persons involved in the preparation of the portions of the SALP Report of April 2,

1984, described at NUREG-0680, Supp.

5, p.

7-14, related to GPU training, including those who did the reviews and evaluations and those, if different, who drafted the relevant sections of the SALP.

They should bring with them all documentation of that review, including but not limited to to notes, draft and final reports, and input to reports, memoranda, interview notes, evaluations, and any and all other documentation.

They should also bring with them their resumes and statement of qualifications.

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'All persons involved in the preparation of the L

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Operational Readiness _ Evaluation - of TMI-l licensed personnel (February 8 and 9, 1984), described at E

NUREG-0680, Supp.

5, p.

7-14, including those who did the reviews,. interviews, and evaluations, and

-those, if different, who. drafted the evaluation.

They.should bring with them all documentation of.that review, including.but not limited to to

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notes, draft and final reports, and input to e.

reports, memoranda, interview notes, evaluations, and any and all other. documentation.

This includes, but is not limited t ),

the notes.and evaluations of interviews with 26 licensed operators, the questions asked in those interviews, and.the answers given.

They should also bring with them their resumes and statement of qualifications.

LExcept as otherwise agreed, these. depositions will be taken in the order stated above at the offices of UCS' attorneys, Harmon, Weiss, & Jordan, 2001~S Street, N.W.,

Suite 430, Washington,-D.C.

The first deposition will begin at 10:00 a.m.

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.on Monday," October 29, 1984,-and'.the' depositions will continue thereafter,until-they'.are; completed.

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-Respectfully submitted, S

.' ^hdy' Ell n R. Weiss '

-V4 SYS William S., Jordan, III d'-

HARMON, WEISS, & JORDAN

.2001 S Street, N.W..

Suite 430 Washington, D.C.

20009 (202) 328-3500 Dated:

October 16, 1984

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October 16, 1984 m:

s-UNITED STATES-OF AMERICA NUCLEAR REGULATORY COMMISSION -

In_ the Matter ofL

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' METROPOLITAN EDISON COMPANY

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' Docket No. 50-289

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(Restart Remand on

'(Three Mile : Island Nuclear

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Management)

Station, Unit No. 1)

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CERTIFICATE OF SERVICE l

~I.herebyfcertify that-(copies of-the UNION OF~ CONCERNED

. SCIENTISTS' NOTICE OF DEPOSITION OF CERTAIN GPU PERSONNEL and

. UNION 0F CONCERNED SCIENTISTS'.SECOND NOTICE OF DEPOSITIONS TO NRC STAFF, October 16, 1984, were served on the following by depositLin The United States mail, first class, postage prepaid, on: October 16,.1984.

William S. Jordan, III

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UNITED STATES OF-AMERICA 1,

NUCLEAR REGULATORY COMMISSION L

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the. Matter of

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. METROPOLITAN EDISON-COMPANY

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Docket No. 50-289

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(Restart Remand on (Three Mile Island Nuclear

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Management)

' Station, Unit No. 1)

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SERVICE LIST IAdministrative' Judge

Gary J.

Edles, Chairman

  • Jack R. Goldberg, Esq.

Atomic Safety & Licensing Appeal Bd.

Office of the Executive Legal Dir.

JU.S. Nuclear Regulatory Commission U.S.

Nuclear Regulatcry Commission jWashington, D.C.

20555 Washington, D.C.

20555 LAdministrative Judge

  • Ernest L.

Blake, Jr. Esquire Jonn H.

Buck Atomic 'Saf ety & Licensing Appeal Bd.

Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

'Wrsnington,-D.C.

20555 Washington, D.C.

20036

' Administrative Judge Christine M.

P.ohl Mr. Louise Bradford Atomic Safety & Licensing Appeal Bd.

TMI Alert

'U.S. Nuclear Regulatory Commission 1011 Green Street

'Wcanington, D.C.

20555 Harrisburg, PA 17102 2 Administrative Judge Iv;n W.

Smith, Chairman Joanne Doroshaw, Esquire Atcmic Safety & Licensing Board The Christic Institute

-U.S.~ Nuclear Regulatory Commission 1324 North Capitcl Street W 2hington, D.C.

20555 Washington, D.C.

20002

. Administrative-Judge Shaldon J. Wolfe Mr. and Mrs. Norman Aamodt

Atomic Safety & Licensing Appeal Bd.

R.D.

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U.S. Nuclear Regulatory Commission Coatesville, PA 19320

~WOShington, D.C.

20555 Administrative Judge Lynne Bernabel, Esq.

Gugtove A.

Linenberger, Jr.-

Government Accountability Project

,I,_' A tomic Saf e ty &

Licensing Board 1555 Connecticut Ave.

-U.S. Nuclear Regulatory Commission Washington, D.C.

20009 Wsshington, D.C.

20555 a

D;ckOting and Service Section Michael F.

McBride, Esq.

Office of the Secretary LeBoeuf, Lamb, Leiby & MacRae

..U.S. Nuclear Regulatory Commission 1333 New Hampshire Ave, N.W.

  1. 1100

'WCchington, D.C.

20555 Washington, D.C.

20036

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h.!Michsc1 W.~Miupin,-Esq.

.Hunton:6 Williams

707 East
Main Street
P.O., Box 1535 c

-Richmond,.VA. 23212 LThomas:Y. Au, Esq.

Office of' Chief' Counsel g;

Department.ofcEnvironmental Resources 505 Executive Houses.

P.O.:cBox-12357

.Harrisburg, PA 17120-2 Hand delivered

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