ML20096F264
| ML20096F264 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/04/1984 |
| From: | Jordan W, Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20096F268 | List: |
| References | |
| SP, NUDOCS 8409070368 | |
| Download: ML20096F264 (5) | |
Text
$9b0'
- Sept:mbar-4, 1984::7. :I n
t7-'^
^-'M
- . C l.','CZ U::ITED STATES OF A:IERICA MUCLEAR REGULATORY COMMISSION Before the Executive Director for Ooerations il 9-'n,.:
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart - Management Phase)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
UNION OF CONCERNED SCIENTISTS' FIRST REQUEST TO THE EXECUTIVE DIRECTOR FOR CPERATIONS FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R.
S 2.744, the Union of Concerned Scientists requests the Executive Director for Operations to make
~
the documents described below available for inspection and copying in connection with this proceeding.
DEFINITIONS (a)
The Nuclear Regulatory Commission or "NRC" shall mean the Nuclear Regulatory Commission, its branches, departments, s:ctions, offices, subdivisions, its present and former commissioners, administrators, management, employees, staff, cgents, representatives, consultant 0, officials, inspectors, investigators, auditors and accountants, attorneys or their cgents, attorneys or representatives.
(b)
" General Public Utilities" or "GPU" shall mean General Public Utilities, any of its subsidiaries, including but not 8409070368 840904 PDR ADDCK 05000289 bSC:3
s
~
~
r
_2_
' limited to GPU Nuclear Corporation and Metropolitan Edison Com l
any', and its subsidiaries' branches, diticions, departments, sections, affiliates, offices, pre:ent and former officers, i
. directors,' management, board of directors, employees, staff, I
j officials, agents, consultants, attorneys representatives and o
their attorneys, representatives and agents.
(c)
" Document" shall mean every writing of every type or d2scription, and every other instrument or device by which, through which or on which information has been recorded and/or preserved, including but not limited to memoranda, notes, lotters, drawings, files, graphs, charts, photographs, slide presentations, handwritten notes, logs, ledgers, studies, data cheets, appointment calendars, telephone messages, meeting minutes, calculations, computations, financial statembnts, voice recordings and other data compilations or every other device or m:dia on which or through which information of any type is transmitted, recorded or preserved.
(d).
" Person" shall refer to any natural person, firm, partnership, joint venture, trust, corporation, holding company or other entity, natural or legal, domestic or fore.gn.
(e)
" Communication: shall mean discussion, conversation, letter, memorandum, telephone call, message or direction, whether written or oral or whether in person, by telephone of by mail.
. m
gy
. v., -
l: G ' -
_3
?lb:l,
r -
(f), '"SpecialTReport" shall meanethe Special Report-or'the Reconstitutsd[OARP-l Review Committee, dated June 12, --1954.
2
-INSTRUCTIONS FOR USq A'.Ef ouimust mak'e1available for' inspection or copying all documents that areLin?your possessi~on'or under your control, or.
- in-the possession or.:under the-control of-your officers, i
msnagement, executives, employees, staff,- directors, officials, fattorneys, consultants, accountants, inspectors, investigators, or representatives, or their agents, representatives or-attorneys.
-B..-If NRC contends that any' document responsive to any
~
requestLfor production listed below is privileged in.whole or in part, or otherwise objects to any part o'f any request, state the-
[
'rcason'for each' objection or. grounds for exclusion,-and identify
.each' person having knowledge of the factual basis, if any, on I
which the privilege or other ground is asserted.
{
C.-
If any document responsive to any request for production p
is no longer in, existence, then answer the following questions:
(1) identify what-information was maintained in that document; i
(2) identify the' type of document which contained such s
i information; n
(3) ; state the time period during which such document was maintained;
-(4) state the circumstances under which such document
.coased to exist; i
l.
'(5)'
state the date when such document ceased to exist;
m M
y
^ (6) identify all persons having knowledge of the circunstancec under which such document Osased to exist; and (7) identify all persons uha hrca kncwledge or had knowledge of the document and the contents thereof.
This Regaest for Production is deemed to be continuing such that NRC is requested to supplement production with all rcsponsive documents which come into its possession, custody or control subsequent to production of documents pursuant to intervenor's request.
' NOTE ON NONDUPLICATION UCS has attempted to avoid duplication of document requests made by other intervenors.
.Should such duplication occur despite our efforts, you may identify the duplicative document request and the documents that you have provided in response to another intervenor's document request that you believe are responsive to UCS' document request.
Should UCS' document request be broader than the other intervenor's, you must provide the additional documents as well as identifying those that you have already provided.
-~
.y
g
?
~
--S-DOCUMENTS ~RE00ESTED 1..
- All documents identified in response to the-following Interrogatories'.in UCS' -First Set of Interrogatorier to liRC
. Staff:- Interrogatory 2(c), 2(d)(testimony), 2(e), 2(g), 5(d),
5(f),-6'.(examinations), 7(c). 9(e), 14, 15, 16, and 19.
UCS'
.First Set of Interrogatories to NRC Staff accompanies to this document request for your reference.
2.
'All documents describing, explaining, or providing instructions or directions for the process by which written and oral examinations are designed and questions prepared by the NRC Staff.,
3.
All documents related to any review or evaluation of the GPU training program by the NRC Staff, its agents or consultants, since March 1979.
4.
All documents related to the performance of GPU employees since March 29, 1979, on examinations administered by GPU or the NRC Staff.
All of these documents are relevant to this proceeding b cause they bear upon the GPU training program and methods by which _that program is or can be evaluated.
Respectfully submitted, (W' ? /Wh
/
O'//'
Ellyn R., Weis
/
<hj
-6 William S ordan,s/
III HARMON, WEISS, & JORDAN 2001 S Street, N.W.
Suite 430 Washington, D.C.
20009 Dated: - September 4,1984 -
(202) 328-3500 c - __
. --=_