ML20096D117
| ML20096D117 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/04/1984 |
| From: | Bernabei L, Doroshow J CHRISTIC INSTITUTE, GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT |
| To: | GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20096D092 | List: |
| References | |
| SP, NUDOCS 8409050562 | |
| Download: ML20096D117 (8) | |
Text
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4 TMIA - 9/4/84 p.
UNITED STATES OF AMERICA RCLU " C_
- CNDENCE KUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board D?METCn In the Matter of
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),
METROPOLITAN EDISON COMPANY
),
Docket No. pp a$p'mtntlEPJJase) 2 JP
)
(Restart - Man ge,
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
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G; ;
THREE MILE ISLAND ALERT'S THIRD SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO GENERAL PUBLIC UTILITIES To:
GENERAL PUBLIC UTILITIES NUCLFAR CORPORATION Pursuant to 10 C.F.R. 2.740b and 2.741, intervenor Three Mile Island Alert ("TMIA") requests that licensee General Public Utilities Nuclear Corporation ("GPU") answer separately, fully in writing, and under oath or affirmation, each of the following inter-rogatories, by or before September 18, 1984, and produce'and make available for inspection and copying the original or best copy of all documents identified in the response to these interrogatories.
These interrogatories and requests for production are deemed to be continuing, and any additional information or documents relating in any way to these interrogatories or request for produc-tion which GPU acquires subsequent to the date of its response, up to and including the time of hearing, should be furnished to intervenor promptly after such information or documents are acquired.
8409050562 840904 PDR ADOCK 05000289 Q
4 INSTRUCTIONS-A.
All information is to be divulged which is in your possession or under your control, or is in the possession or under the control of your present cn former managers, officers, directors, executives, employees, staff, attorneys, consultants, accountants, or their agents, representatives or attorneys.
B.
Where an individual interrogatory calls for an answer which involves more than one part, each part of the answer should be set out so that it is clear to which interrogatory it refers.
C.
Where identification of a person is required, state the following:
his/her. full name; his/her current home and business address; if his/her current addresses are not known, his/her last known home and business address; the position (s) he/she held with-GPU at any time; his/her home and business address at the time for which the interrogatory requests information; his/her current employer and position.
D.
Where identification of a document is required, state the following:
its date; its exact title; the general subject matter of the document; the author and his/her affiliation, office or business, presently and at the time the document or correspondence was prepared; the last known address of every person to whom a copy of the document was to be sent, other than the addressee described above; the name and address of all persons who now have the original-and/or copies; the identification and location of the files where~the original and each copy is kept in the regular course of business and the custodian thereof; and whether the document will be made ava'lable for inspection and copying, and the site of such voluntary i
production.
~
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3-i g:E.' IffGPU contends.that-the answer to any interrogatory is
~~ privileged,_in whole.or-in part', or otherwise objects to any part of.any-interrogatory, state the reasons for each objection or
,: grounds for exclusion, and-identify each person having knowledge of the~ factual basis, if any, on which the privilegeLor other ground 1
is asserted.
t F.-
If an~' interrogatory could, at one time, have been answered-Eby consulting. documents which are no longer in existence, in answer i
to such interogatory:
1.
.identifyfwhat information was maintained; 2..
identify all' documents which contained such information; i
3.
state the; time period during whi:h such' documents T
were maintained; 4.
state the circumstances under which such documents ceased to exist;
-5.
state the date when such documents. ceased to exist;
]
6.
identify all persons having knowledge of the circum-stances under'which such documents ceased'to exist;-and 7.
identify all persons who have knowledge or had know-L
' ledge of the documents and their contents.
G.
'As used herein and unless.the context otherwise required, the terms:
(i)
"NRC"'shall mean the Nuclear Regulatory Commission, its branches, departments, sections, offices, subdivisions, its present and former commissioners,. administrators, officials, L
. inspectors, investigators, staff, consultants, contractors, attor-
-neys,, employees, agents, representatives and accountants, or their agents, attorneys'and representatives.
~
4_
~
.(ii)
" General Public' Utilities" or "GPU" shall mean
' General Public Utilities, any of'its subsidiaries, including but not limited to GPU Nuclear Corporation and Metropolitan Edison Company, its or its subsidiaries' branches, divisions, departments, sections,-affiliates, offices, present and former officers, directors, I
mamangement, board of. directors, employees, staff, officials, agents, consultants, attorneys, representatives or their attorneys, repre-sentatives and agents.
T-(iii)
" Document" shall mean every writing of every type and description, and every other instrument or device by which, through whichlor on which information has been recorded and/or preserved, including but not limited to memoranda, including those reflecting meetings, discussions or conversations, notes, letters, drawings, files, graphs, charts, maps, photographs, deeds, agreements, contracts, handwritten notes, diaries, logs, ledgers, studies, data l:
sheets, notebooks, books, appointment calendars,. telephone bills, telephone messages, receipts, vouchers, minutes of meetings, pam-phlets, computations,-calculations, accounting (s), financial state-ments, voice recordings, computer printouts, computer discs and-programs, and other data compilations, device or media on which or through which information of any type is transmitted, recorded or
' preserved.
The term " document" also means every copy of a document when such copy is-not an identical duplicate of the original.
.(iv)
" Person" shall refer to any natural person, firm, partnership, joint venture, trust, corporation, holding company, or any other entity natural or legal, domestic or foreign.
(v)
" Communication" shall mean communication, discussion,
-conversatisn, contact, letter, memorandum, telephone call, telegram,
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' message or direction,'whether written ~or oral', and whetherein person,
.bygtelephonefor byJmail.
INTENROGATORIES-
-Identify all~ persons GPU/ intends to call as a witness on the 1remanded issue of-the'Dieckamp mailgram.
For_each such person-identified above, identify the following:
(a) the nature or substance of his testimony; i
-(b) his qualification,-access _to information, or:other
' reason that he is being asked to-testify as totthe information P
identified in response tofsubpart (a) above; (c) his position or relationship to GPU at any' time'from the time of the' accident-to the present, including but not limited to any contracts, consulting arrangements, advisory positions or other relationships with GPU he has held or holds currently; (d) all documents he has reviewed or will review to prepare his testimony; (e) all persons whom he has consulted or will consult to prepare his testimony; (f) the nature and substance of any discussions, conversa-
~
tions, commun1ations, and other contacts he has had or will have with the persons identified in response to subpart (e) above; (g) all documents he intends to rely on or use in support of any opinions,' evaluations, conclusions, or recommendations he makes in his: testimony; (h)- the current location and custodian of all documents 1
identified in response to subparts (d) and (g) above.
2.
Identify and produce all documents which GPU intends to i.
introduce in the hearing or through prefiled testimony on the
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remanded issue of.thefDi'eckamp,mhilgram.
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3.
Produce all 'Cocuments ifentified. in! response to Inter-
.'[
rogatory No.1(d), (g) ad,0*(h).above.
~
4.
For each person whom GPU,has identified in response to an interrogatory in TMIAs First Set of Interrogatories or Second Set d'
of Interrogatories to General Public Utilities, state the following:
(a) his/her current home and business address; (b) if his/her current addresses are not known, his/her last known home and business address; (c) the positions he/she has held with GPU at any time; (d) his/her home and business address at the time for which the interrogatory requests information; (e) his/her present employer and position.
Respectfully submitted, 0 h a o vt arc %{. A @
Joanne Doroshow The Christic Institute 1324 North Capitol Street Washington, D.C.
20002 Telephone:
202/797-8106
'i f M 2cu Lynde Bernabei Government Accountability Project 1 55 Connecticut Ave. N.W.
W hington, D.C.
20036 Telephone:
202/232-8550 DATED:
September 4, 1984 Attorneys for Three Mile Island Alert
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UNITED STATES OF AMERICh
_.hM NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Three Mile Island Nuclear
)
(Restart - Management Phase)
Station, Unit No. 1)
)
W dp@gbgn I hereby certify that I have served this 4th da o
1984 a copy of the foregoing TMIA's Response to GPU's First Set of Inter-rogatories and Firest Request for Production; TMIA's Motioncfor Heconsideration, or, in the Alterriative, Motion for Directed Certification; TMI A's4U)ird(Set of Inter-rogatories and Third Request for Production to GPU; and TMIA's Sscond Set of Inter-rogatories to NRC Staff on the following by mail, first-class, postage prepaid:
- Administrative Judge Thomas Au, Esq.
Ivan W.
Smith, Chairman Office of Chief Counsel Atomic Safety & Licensing Board Department of Environmental U.S.
Nuclear Regulatory Commission Resources Wa shington, D.C.
20555 505 Executive House P.O. Box 2357
- Administrative Judge Harrisburg, PA 17120 Sheldon J. Wolfe Atomic Safety & Licensing Board John A. Levin, Esq.
U.S.
Nuclear Regulatory Commission Assistant Counsel Washington, D.C.
20555 Pennsylvania Public Utility Commission
- Admini.strative Judge P.O.
Box 3265 Gustave A. Linenberger, Jr.
Harrisburg, PA 17120 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission
- Ernest L. Blake, Jr.
Washington, D.C.
20555 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Docketing and Service Section (3)
Washington, D.C.
20036 Office of the Secretary U.S. Nuclear Regulatory Commission Mr. Henry D. Hukill Washington, D.C.
20555 Vice President GPU Nuclear Corporation Atomic Safety & Licensing Board P.O. Box 480 Panel Middletown, PA 17057 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. and Mrs. Norman Aamodt i
R.D.
5 Atomic Safety & Licensing Appeal Coatesville, PA 19320 Board Panel U.S. Nuclear Regulatory Commission Ms. Louise Bradford Washington, D.C.
20555 TMI ALERT 1011 Green Street Jack R. Goldberg, Esq.
Harrisburg, PA 17102 Office of the Executive Legal r
Director Joanne Doroshow, Esq.
U.S. Nuclear Regulatory Commission The Christic Institute Washington, D.C.
20555 1324 North Capitol Street "9
- Served by hand, Sept. 4, 1984.
~
2
- e o-,
Michael F. McBride, Esq.
Ellyn R. Weiss, Esq.
' 'A.
LeBoeuf, Lamb, Leiby.& MacRae William S. Jordan, III, Esq.
1333 New Hampshire Avenue, N.W.
Harmon, Weiss & Jordan
' Suite'1100
'2001 S Street, Northwest Washington, D.C.
20036 Suite 430
. Washington, D.C.
20009 Michaell W. Maupin, Esq.
Hunton & Williams Jack Thorpe 707 East' Main. Street Manager of Licensing Post' Office Box 1535 General Public Utilities Richmond, VA 23212 100 Interpace Parkway Parsippuny, New Jersey 07054 w
Lw Ly e Bern6bei 6