ML20098A878

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Provides Names of Individuals & Schedule of Proposed Depositions Re Knowledge of Hydrogen Explosion or Combustion on 790328.Related Correspondence
ML20098A878
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/21/1984
From: Bernabei L
GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To: Blake E
SHAW, PITTMAN, POTTS & TROWBRIDGE
References
SP, NUDOCS 8409250290
Download: ML20098A878 (2)


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, GOVERNMENT ACCOUNTABILITY PROJECT L 1555 Connecticut Avenue, N.W., Suite 202 ocwET.EiF Washington, D.C. 20036 (202)Y2"-8550 HAND-DELIVERED 84 SEP 24 P1:15 September 21, 1984 e e- dont u

';. ' 0CKETING & SENI.

0 BRANCH s

Ernest'L. Blake,;Jr., Esquire Shaw, Pittman-, P$tts & Trowbridge 1800 M Street NW # ' " ' m 20036 -k N....,.... 3-Washington, D.C.

Dear Ernie:

'As I' promised last Monday, I am providing you today with the names of those individuals whom we propose to depose concerning their knowledge of a hydrogen explosion or combustion on March 28, 1979.- These individuals and the dates of their proposed. depositions are as follow:

Wednesday, September 26 Th'omas Mulleavy .y(previously scheduled)

Thursdayi September 27

, David Reich (previously scheduled)

Friday, Sep3 ember 28 A.P. Rochino. 9:00 a.m.

James Moore 10:00 a.m.

Thursday, October 4 Richard B$nner 9:00 a.m.

' Robert Boyer 10:30 a.m.

Curtis'Conrad 12:00 nocn George Cvijic 2:30 p.m.

Juanita Gingrich 4:00 p.m.

~

After our conversation today, I realized that Mr. Moore, whom we noticed for a deposition earlier, answered that he was not aware of the hydrogen combustion / explosion on March 28. However, he was aware of in-core thermocouple temperatures in excess of 2500 degrees on March 28, as a result of an assignment he received from Parsippany corporate management to collect information at

.the site.- Therefore, TMIA wishes to depose him on his informa-tion gathering on the in-core, thermocouple data and the persons to whom he distributed that information. I have scheduled Mr.

Moore for the morning of September 28.

2409250290 840921 PDR ADOCK 05000289 0

PDR 563

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- Blcko. Letter September-L 21,-1984

-It h' ave scheduled the' bulk of the individuals who originally

answered Question 3 (a) affirmatively on October 4, 1984, in the

- hope that.GPU's efforts to validate their answers may obviate the need.for their depositions. My expectation is, of course, that we will~ agree to a stipulation which will eliminate the need for a deposition of.Dr. Myers on October 4, 1984.

Sincerely yours,

( [M h V Lynne Bernabei Attorney for Three Mile Island Alert i

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