ML20094R395
| ML20094R395 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/17/1984 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| SP, NUDOCS 8408200557 | |
| Download: ML20094R395 (14) | |
Text
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7, ~,CE August 17, 1984 00Cy)rfD UNITED STATES OF AMERICA Mf NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board O
(g AIOl2l In the Matter of
)
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)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP (Three Mile Island Nuclear
)
(Restart Remand on Station, Unit No. 1)
)
Management)
+
LICENSEE'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR THREE MILE ISLAND ALERT, INC.
These interrogatories and document requests are directed to Intervenor Three Mile Island Alert, Inc. (hereinafter TMIA) and pertain to the reopened hearing on the Dieckamp mailgram.
See Metropolitan Edison Co. (Three Mile Island Nuclear Generating Station, Unit 1), ALAB-772, 19 N.R.C.
slip op, at 128-134 (May 24, 1984).
See also Memorandum and Order Fol-lowing Prehearing Conference (July 9, 1984).
The interrogatories are filed pursuant to 10 C.F.R.
.S 2.740b, which requires that they be answered separately and fully in writing under oath or affirmation, within 14 days after service.
The interrogatories are intended to be continu-ing in nature, and the answers must be immediately supplemented or amended, as appropriate, should TMIA obtain any new or dif-fering information responsive to the interrogatories.
The document production request is filed pursuant to 10 d
C.F.R.
$'2.741, which requires that, within 30 days, TMIA 8408200557 840817
)
PDR ADOCK 05000289 C
'O produce and either furnish copies of, or-permit Licensee to in-spect and copy, any documents that are responsive to the re-quest and that are in the possession, custody, or control of TMIA.
The document production request is also continuing in nature, and TMIA must produce immediately any documents they obtain which are responsive to the request.
Licensee makes these discovery requests of TMIA in its ca-pacity as lead intervenor on the issue of the Dieckamp mail-gram.
Licensee assumes that TMIA's response will reflect the collective knowledge of any intervenor who has an interest in, or desires to participate on, this issue.
If Licensee is in-correct in its assumption, TMIA should promptly inform Licensee so that appropriate discovery requests can be provided to other intervenors as well.
I.
INTERROGATORIES A.
Instructions Any reference to Intervenor Three Mile Island Alert, Inc.
(TMIA) shall be deemed to include all members of TMIA, and any other intervenor and its members on whose behalf TMIA is act-ing.
When knowledge or information of TMIA is requested, such request includes knowledge or information of TMIA's members, employees, consultants, and unless privileged, its attorneys, and also includes the information of any other intervenor on whose behalf TMIA is acting and such intervenor's members, employees, consultants, or attorneys.
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.w When identification of a document is requested, briefly describe the document-(i.e., letter, memorandum, book, pamplet, etc.) and state the following information as applicable to the particular document:
name, title, number, auth,or, date of pub-lication and publisher, addressee, date written or approved, and the name and cddress of the person (s) having possession of the document.
With respect to any interview or deposition, state in addition to the information requested above the name and affiliation of the interviewer or deposer, 'and the date of the interview or deposition.
With respect to any testimony,
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state in addition to the information requested above before whom and on what date the testimony was given.
The following definitions apply to each of the interroga-tories:
1.
" Document" means all writings and records of every type, including, but not limited to, memorandum, correspondence, re-ports, surveys, tabulations, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind.
" Document" shall also mean every copy of a document when such copy is not an identical duplicate of the original.
2.
" Pressure spike" means the increase in the containment pressure that occurred at Three Mile Island, Unit 2, at approx-imately 1:50 p.m. on March 28, 1979, or the corresponding re-cordings on any strip recorder or other instrument, or the cor-responding actuation of any alarm. <-
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3.
" Spray actuation" means the activation of_ containment sprays at Three Mile Island Unit 2 at approximately 1:50 p.m.
on March 28, 1979.
4.
"The " thud" refers to the thud or similar noise that was heard at Three Mile Island Unit 2 at approximately 1:50 p.m.
en March 28, 1979.
5.
The "Dieckamp mailgram" refers to the mailgram from Herman Dieckamp to Senat,or Morris Udall dated May 9, 1979.
B.
Specific Interrogatories 1.
(a)
State the name, address, title, employer, and educational and professional qualifications of each person you intend to call as a witness in the reopened hearing.
(b)
State the substance of the facts and opinions to which each such person is expected to testify.
(c)
State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.
2.
Identify all documents in your possession, custody, or control, including all relevant page citations, pertaining to the following:
(a) the pressure spike, hydrogen combustion, or hy-drogen explosion which occurred at Three Mile Island Unit 2 at approximately 1:50 p.m. on March 28, 1979.
(b) the actuation of the containment sprays at TMI-2 at approximately 1:50 p.m. on March 28, 1979..-
- n (c) a " thud" or similar noise that was heard at at
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TMI-2 at approximately 1:50 p.m. on March 28, 1979.
(d) any order, instruction, request, recommendation, or' suggestion by anyone on March 28, 1979 through March 30,
- 1979 to the effect that oil pumps or other electrical equipment at TMI-2 should not be turned in.
(e) a zirconium-water reaction or the generation of hydrogen at TMI-2 on March 28, 1979.
(f) the mailgram from Herman Dieckamp to Senator Morris Udall dated May 9, 1979.
3.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during the re-opened hearing,.or which you intend to use during cross-examination of witnesses presanted by Licensee or the NRC.
4.
(a)
Identify every individual who, on March 28, 1979, was aware of the pressure spike or spray actuation, or who heard a thud.
(b)
For every individual identified in your response to Interrogatory 4(a) above, identify all statements, inter-views, depositions, or testimony of that individual that were given prior to May 9, 1979.
(c)
For every individual identified in your response to Interrogatory 4(a) above, identify all documents discussing that individual's awareness of the pressure spike, spray actuation or the thud.
Provide page citations.
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I 5.
(a)
Identify every individual.who', on March 28, 1979, associated the pressure spike, spray actuation, or the
" thud" with a-hydrogen combustion or explosion.
(b)
For each individual identified in your response to Interrogatory 5(a):
(i) explain precisely why you believe that individ-ual associated the pressure spike, spray actuation, or " thud" with a hydrogen combustion or explosion.
(ii) identify all documents discussing that associa-tion.
Provide. page citations.
6.
(a)
Identify, every individual who, on March 28, 1979, associated the pressure spike, spray actuation, or the
" thud" with core damage.
(b)
For each individual identified in your response-i to Interrogatory 6(a) above:
(i)
Explain precisely why you believe that individ-ual associated the pressure spike, spray actuation, or " thud" with core damage.
(ii)
Identify all documents discussing that associa-tion.
Provide page citations.
7.
(a) on what date during period from March 28 to March 30, 1979, at what time, and by whom was any order given to the effect that oil pumps of other electrical equipment at TMI-2 should not be turned on or energized?
(b)
Identify every individual who heard, received, or learned of such order.
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(c)
With respect to your responses to Interrogato-ries 7(a) and (b), identify all documents upon which you rely to support your responses, and provide all relevant page cita-tions.
8.
(a)
On what date did Mr. Herman Dieckamp learn or
'know that any individual had interpreted the pressure spike or spray actuation in terms of core damage at the time of the spike?
(b)
Explain precisely the basis for your answer to Interrogatory 8(a) above.
Identify all documents upon which you rely to support your response, and provide all relevant page citations.
9.
(a)- If on or before May 9, 1979, Mr. Dieckamp did not know that any individual had interpreted the pressure spike or spray actuation in terms of core damage, should he have known?
(b)
Explain precisely the basis for your answer to Interrogatory 9(a) above.
Identify all documents upon which you rely to support your response, and provide all relevant page citations.
10.
(a)
Was the Dieckamp mailgram false or misleading?
(b)
Explain precisely the basis for your answer for Interrogatory 10(a) above.
Identify all documents upon which you rely to support your response and provide all relevent page citations. _ _ _. -
I 11.
(a)
Should Mr. Dieckamp have corrected the mailgram?
(b)
If so, on what date?
(c)
Explain precisely the basis for your answers to Interrogatories 12(a) and-(b) above.
Identify all documents upon which you rely to support your responses and provide all relevant page citations.
12.
(a)
How does the Dieckamp mailgram bear on Licens-ee's management integrity or capability?
(b)
Explain precisely the basis for your answer to Interrogatory 11(a) above.
Identify all documents upon which you rely to support your response, and provide all relevant page citations.
13.
TMIA's First Set of Interrogatories to General Public Utilities (July 31, 1984) and TMIA's First Request for Produc-tion to General Public Utilities (July 31, 1984) indicate the compilation of or familiarity with considerable background information.
State the name, title or position, address, and employer of each person who prepared, or who provided informa-tion used in preparing, or who was contacted in connection with the preparation of, TMIA's discovery requests.
Include in your answer any staff member of the House Committee on Interior and Insular Affairs or of any of its subcommittees. The' purpose of this interrogatory is to identify potential witnesses and/or deponents. -.
i C.
General Interrogatorics 14.
State the name, title or position, address, and em-ployer of each person who provided information used in preparing responses to any of the foregoing interrogatories.
15.
For each person identified in response to the pro-ceeding interrogatory, state the number of the* interrogatories for which information was supplied.
16.
State the name, title or position, address, and em-ployer of each person who searched for documents in order to respond to any of the foregoing requests for identification of the documents.
17.
For each person identified in response to the pro-ceeding interrogatory, state the numbers of the interrogatories for which the search was conducted and the location where the search was condu'ted.
c
- 18. Identify any written or recorded statement of any individual which you claim pertains to the subject matter of the reopened hearing on the Dieckamp Mailgram and which has not been previously identified in response to the foregoing inter-rogatories.
19.
For each document identified in your responses to any of the foregoing interrogatories, identify the person (s) who provided TMIA with that document, or any copy thereof, his title or position, address and employer.
Include in your an-swer any staff member of t'he House Committee on Interior and Insular Affairs or of any of its subcommittees.
Also identify 9_
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1 the date on which that document was provided and the circum-stances under which it was provided.
II.
REQUEST FOR PRODUCTION OF DOCUMENTS Licensee requests that TMIA respond in writing to the fol-lowing request for production of documents and produce or make available for copying the original or best copy of each of the documents requested below, at a designated location.
The term " document (s)" means all writings and records of every type in the possession, control or custody of TMIA, its members, employees, or attorney (s), or and in the possession, control, or custody of any other intervenor whose behalf TMIA is acting.
The term " document (s)" includes, but is not limited to, memoranda, correspondence, reports, surveys, tabulations,_
charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice records, and all other writings or recordings of any kind.
"Docu-ment (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody or control of the TMIA.
A document chall be deemed to be within the " control" of the TMIA or TMIA's attorney (s) if they have ownership, posses-sion or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or privite entity having physical possession thereof.
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b6 l-Licensee requests that TMIA produce cur make available for copying each and every document identified or described in the answers to Interrogatories 1 through 18 above.
Respectfully submitted, SHAW, PITTMAN, POTTS AND TRdWBRIDGE ht,yj!'l. / $b).
~
George F. Trowbridge, P.C.
Ernest L. Blake,~P.C.
David R.
Lewis Counsel for Licensee 4
Dated: August 17, 1984 i
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I August 17. 1984 CCC4!!Er UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0A A33 20 go:gy BEFORE THE ATOMIC SAFETY AND LICENSING BOARD;; p,
C O;RA!;cy ig g, g; U
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Second Set of Interrogatories and Request for Production of Documents to Intervenor Three Mile Island Alert, Inc." were served this 17th day of August, 1984, by hand delivery to the parties identified with an asterisk and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
(p. } 'Y. /h54),
Ernest L.
Blake, Jr., P.C.
s-.
.i UNITED STATES OF AMERICA NUCLEAR. REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.In the Matter
)
)
METROPOLITAN EDISON COMPANY
-)
Docket 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. Kohl 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 1
l Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge i
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 i
r.
o
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 Washington, 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.
Gover ment Accountability Jack R.
Goldberg, Esq. (4)
Office of the Executive Legal 1555 Connecticut Avenue Washington, D.C.
20036 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 l
l Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707
.st Main Street P.O. Box 1535 Richmond, VA 23212 l
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