ML20094R405
| ML20094R405 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/17/1984 |
| From: | Doris Lewis METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| References | |
| SP, NUDOCS 8408200561 | |
| Download: ML20094R405 (6) | |
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I Lynne Bernabei, Esquire i'g Government Accountability Project 1555 Connecticut Avenue, N.W.
Suite 202 Washington, D.C.
20036 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)
Docket No. 50-289 SP
Dear Lynne:
On August 13, 1984, you met with Mssrs. Trowbridge and Blake and myself to discuss TMIA's First Request for Production to General Public Utilities (July 31, 1984) and TMIA's First Set of Interrogatories to General Public Utilities (July 31, 1984).
During this meeting, we agreed to a number of changes to these discovery requests.
This letter is written to memorialize the changes.
TMIA's Document Request No. 7 now reads:
7.
Any checks made of plant conditions and/or the containment within four hours after observance of the pressure spike and/or the activation of the reactor building spray pumps at about 1:50 p.m. on March 28, 1979, including but not limited to the checks of the plant conditions and containment reported by Mr.
Rogers, Mr. Chwastyk and Mr. Mehler in inter-views and reports to the NRC and to GPU.
8408200561 840817
{DRADOCK 05000289 s}o eDe
SHAW, PITTMAN, PoTTs & TROWBRIDGE Lynne Bernabei, Esq.
August 17, 1984 Page two TMIA's Interrogatory No. 2 now reads:
2.
Describe all lines and methods of communi-cation and/or reporting between the NRC and GPU which existed on March 28, 1979.
State the following for each such line or method of communication and/or reporting identified above:
(a) the method or line of communication, whether by telephone, in person, by tele-type or by some other method; (b) each person participating in each such method of communication; (c) the precise time each such method or line of communication was first utilized on March 28, 1979; (d) the precise length of time on March 28, 29, or 30, 1979, such method or line of communication was maintained; (e) each person, who although not participating, had the opportunity to overhear and/or learn of the information transmitted by means of such method or line of communication on March 28, 1979; (f) all persons named in Document Request number 6 who overheard, or saw, or learned from any individual involved in the communication about, the communications, and the time, date and/or reason for that person being informed of such communications; (g) the person who on March 28, 1979, initiated, suggested or recommended setting up each new method or line of communication and/or reporting listed above; (h) identify any documents which refer to, mention, memorialize or otherwise concern the availability or use of any such method or line of communication on March 28, 1979.
~.
SHAW. PITTMAN, PoTTs & TROWBRIDGE A P&ntNERSMip Or pmOFESSIONAL CQmpomattONS Lynne.Bernabei, Esq.
August 17, 1984 Page three Subparts (a) through (g) of TMIA's Interrogatories Nos. 4, 5, 6 and 7 now state:
(a) the method or line of communication, whether by telephone, in person, by tele-type or by some other method; (b) the persons participating in each such method or line of communication or reporting, and the substance of his/her participating; (c) the persons who heard or saw any communications deucribed above; (d) the precise time each such method or line of communication was first utilized on March 28, 1979, and the length of time on March 28, 29, or 30, 1979, it was maintained; (e) persons who overheard, saw, or learned from any individual involved in the communica-tions about, the communications described above, and the time, date, reason and method by which these persons were so informed; (f) persons.who initiated, suggested, or recommended initiation of each new method or line of communication and/or reporting described above; (g) all documents which refer to, mention, memorialize or otherwise concern the availa-bility or use of any such method or line of communication and/or reporting described above.
TMIA's Interrogatory No. 9 now asks:
9.
Identify the precise ay and time for the three-day period from M,s -h 28 through March 30, 1979 that any member f the Command Team and/or think tank had any concern regarding j
i
_._ -- _,_____, l
1 SHAW, PITTMAN. PoTTs & TROWBRIDGE A pamfhEMMip OF pamFESSi@eAL CommeATIONS Lynne Bernabei, Esq.
August 17, 1984 Page four the presence of hydrogen in the containment or reactor coolant system and for each such incident, identify all persons who held such a concern.
Identify any conversations, discussions, meetings or communications regarding such concerns and all indicators of the condition of the plant which led that person or persons to hold such a concern.
Identify any action taken in response to such concerns.
Finally, TMIA's Interrogatory No. 42 now asks:
42.
Describe all checks which were made of plant conditions and/or containment within four hours after the occurrence of the pressure spike and/or the activation of the reactor building spray pumps.
For each such check described above, state the following:
(a)
The person or persons who made such check; (b)
Any document referring to, recording, memorializing or otherwise concerning any such check; (c)
Any action taken as a result of or in response to any such check; (d)
All persons who were informed on March 28, 1979 of the results of such checks and any action he took as a result a
of or in response to that information.
If I have incorrectly worded any of the changes upon which we agreed, please contact me immediately.
Sincerely, ec.
~
David R.
Lewis Counsel for Licensee cc Per attached service list
- rp 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 i
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 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
__x...,
k l 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 ashington, 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 Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, VA 23212
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