ML20094P699
| ML20094P699 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/15/1984 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20094P693 | List: |
| References | |
| SP, NUDOCS 8408170330 | |
| Download: ML20094P699 (6) | |
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gggTED COREgs?ONDENb i
],]ETED August 15, 1984 g
'84 /g] }g Pf2:51 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FFiCE., ~..,.
00CKLiihj"fC
A M b wV BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gR In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP
)
(Restart Remand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
LICENSEE'S REQUEST FOR EXTENSION OF TIME TO RESFOND TO TMIA'S FIRST SET OF INTERROGATORIES 5
On July 31, 1984, TMIA served on Licensee by mail its I
First Request for Production and a related First Set of Inter-rogatories.
Under the NRC Rules of Practice Licensee's re-sponse to the document request would normally be due on September 4, 1984, and licensee's response to the interrogato-l ries would be due August 20, 1984.
Licensee requests that the l
time for response to TMIA's First Set of Interrogatories be ex-tended to.the same date as the related TMIA document request, i
namely September 4, 1984.
I I
8406170330 840815 PDR ADOCM 05000289 0
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'By separate motion Licensee has today filed with the Board a motion for-protective order limiting the scope of TMIA's dis-covery requests.
Even assuming Licensee's motion is granted,
-however, Licensee is still confronted with a massive set of in-terrogatories which simply cannot be answered in the normal time for-interrogatory responses. This is largely because many of the interrogatories call for new or updated information which-is sought from present and past GPU and B&W personnel.
TMIA is not satisifed with information presently available to
. Licensee's management or contained in the multiple official ac-cident reports and investigations.
It has taken Licensee some two weeks just to compile a list, not yet complete, of the individuals to whom question-naires seeking information must be sent.
Because Licensee has no complete list of all persons in the TMI control rooms on i
March 28-30, 1984, the list includes all persons who were at the TMI site on those days and already totals over 400 persons.
That is not to say that all of these individuals, or even a large number of them, will have information pertinent to the i
interrogatories.
The questionnaire is necessary in part to find out which individuals do have such information.
It has also taken Licensee about two weeks to digest the interrogato-ries and to prepare a questionnaire responsive to the information sought. :
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TMIA's counsel has advised Licensee's counsel that TMIA would not object to an extension of time until August 27, Licensee will, however, be hard put to prepare and send 1984.
out the questionnaire. receive replies, correlate the informa-tion obtained and prepare responses to the interrogatories even by September 4.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE b) h fs g orgs F.
Trowbridge, f.C.
1900 M Street, N.W.
Washington, D.C.
20036 (202) 822-1026 Dated:
August 15, 1984
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UNITED STATES OF AMERICA ccrwrigg NUCLEAR REGULATORY COMMISSION gijrfriC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'84 AG016 R2:50 In the Matter of
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h'hkgn3 f NNi[.
)
Docket No. 50-289 SP BRANCH METROPOLITAN EDISON COMPANY
)
(Restart Remand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Motion for Protective Order" and " Licensee's Request for Extension of Time to Respond to TMIA's First Set of Interrogatories", dated August 15, 1984 were served on those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 15th day of August, 1984.
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DATED: August 15, 1984
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD
-In the Matter
)
)
-METROPOLITAN EDISON COMPANY
)
Dccket No. 50-289 SP
)-
(Restart Remand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST.
Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H.
Buck-Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
-Washington, D.C.
20555 Washington, D.C.
20555 Administrative. Judge James K. Asselstine, Commissioner Christine N. KohlL '
U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commission Frederick Bernthal, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Administrative Judge Ivan W.
Smith, Chairman Lando W. Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge
- Administrative Judge Gary J. Edles, Chairman Sheldon J.-Wolfe Atomic Safety & Licensing Appeal Atomic Safety &' Licensing Board Board-U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 n
y-
- 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)
Mr. and Mrs. Norman Aamodt Office of.the Secretary R.D.
5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Wanr.1ngton, D.C.
20555 Ms. Louise Bradford Atomic Safety-& Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C.
20555 Joanne Doroshow, Esquire Atomic Safety & Licensing 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)
P c
Office of the Executive Legal 1555 Connecticut Avenue Washington, D.C.
20009 U.S Nuc ear Regulatory Commission 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 LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.
Harrisburg, PA 17120 Suite 1100 Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, VA 23212 o
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