ML20098B807

Notice of 841004 Deposition of W Marshall in Harrisburg,Pa Re Dieckamp Mailgram Issue.Svc List Encl.Related Correspondence

ML20098B807
Person / Time
Site:	Three Mile Island
Issue date:	09/24/1984
From:	Bernabei L, Doroshow J CHRISTIC INSTITUTE, GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To:
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ML20098B801	List: ML20098B799 ML20098B803 ML20098B807
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SP, NUDOCS 8409260290
Download: ML20098B807 (8)

Text

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'84 SEP 25 P3:03 i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

[0C ii U I i[h BRANCP Before the Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart-Management Phase)

(Three Mile Island Nuclear ) .

Station, Unit 1) )

)

NOTICE OF DEPOSITION OF WALTER MARSHALL ~

PLEASE TAKE NOTICE THAT intervenor Three Mile Island Alert

(" TMI A" ) will take the deposition of Walter Marshall, currently employed by licensee, on Thursday, October 4, 1984 at 3:00 p.m.

at the Friends Meeting House, 6th and Herr Streets (1100 6th St. ) ,

Harrisburg, PA, 17102. TMIA seeks testimony from Mr. Marshall related to the Dieckamp mailgram issue presently before this Atomic Safety and Licensing Board.

Said deposition will begin at 3:00 p.m. and will continue thereafter until completed.

Respectfully submitted, w$ 'm (_ b Joanne Doroshow /

The Christic Institute 1324 North Capitol Street Washington, D.C. 20002 (202) 797-8106 8409260290 840924 DR ADOCK 05000289 PDR

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. Lyn Bernabei G ve ent Accountability Project Connecticut Ave..N.W.

S te 202 Washington, D.C. 20036 (202) 232-8550 DATED: September 24, 1984 Attorneys for Three Mile Island Alert 1 -

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g U%RC Before'the Atomic Safety and Licensing Board

In the' Matter of ) *84 EP 25 P3:03

)

METROPOLITAN EDISON COMPANY )- Docket No. 50-289 pI.if.E Or n W ij.n .

)

(Three Mile ; Island Nuclear Station, Unit No. 1)_'

)

)

(Restart - Managemen h[

I hereby certify that a copy.of'the foregoing TMIA's Fourth

. Set of Interrogatoires to Licensee; TMIA's Supplemental' Response to Licensee's First Set of Interrogatories; and Notice of Deposition of Walter Marshall have been served this 24th day of September, 1984, by mailing a copy first-class postage prepaid to the following:

SERVICE LIST 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 Washington, 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 Administrative Judge P.O. Box 3265

Gustave A. Linenberger, Jr. Harrisburg, PA 17120

. Atomic Safety & Licensing Board-JU.S.. Nuclear Regulatory Commission

• Ernest L. Blake, Jr.

Washington,LD.C.- 20555 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

- Docketing and Service Section (3) Washington, D.C. 20036 Officecof 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 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 Director Joanne Doroshow, Esq.

U.S. Nuclear-Regulatory Commission The Christic Institute '

Washington, D.C. 20555 1324 North Capitol Street Washington, D.C. 20002 e-e=re-$im=a ge egwe-eugrP wWe eeW*---="*e-.r-e3--eev**v*r 'e'-* ' -

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I j 6 Michael F. McBride, Esq. Ellyn R. Weiss, Esq.

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 Michael W. Maupin, Esq.

Hunton & Williams 707' East, Main Street TMI-PIRC Legal Fund Post Office Box 1535 Richmond, VA 23212 1937 g,et,y Harrisburg, Penn. 17103

[,4,'ij-5L As N-Ly5ru Bernabei

• Served by hand.

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2 RElATEDCokiGPONDENCE GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 COLMETED k unc Washington, D.C. 20036 (202)232-8550 HAND-DELIVERED i

September 24, 1984 CF6Ct t; ;i Q J.T 00CKEgtggERN George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street. N.W.

Washington, D.C. 20036

Dear Mr. Trowbridge:

In accordance with our discussion on Friday, September 21, concern-ing our intention to depose Mr. Blake, I am submitting to you a list of questions on two issues.

The first issue is Mr. Blake's knowledge of a September 17, 1980 Memorandum to Mr. Arnold from Mr. Wallace with attachments. Mr. Blake is listed as a recipient of the Memorandum.

The second issue concerns GPU's response to TMIA Interrogatory No.

48 in Licensee's Response to TMIA's First Set of Interrogatories to GPU, which states that Mr. Dieckamp received a copy of GPU's interview of Brian Mehler, dated April 25, 1979, from Mr. Blake on or about January 28, 1981. (Mr. Dieckamp also responds that he was not aware of the NRC inter-view of Mr. Mehler, dated May 17, 1979, and the NRC interview of Mr.

Chwastyk, dated May 21, 1979, until about March,1980.)

The questions I have of Mr. Blake regarding the first issue are the following :

(1) When did you first become aware of the September 17, 1980, Memorandum from Mr. Wallace to Mr. Arnold? Describe the circum-stances under which you learned of the Memorandum.

(2) When did you first become aware of the " Moore notes" attached to this Memorandum, which constitute the 10 handwritten pages immediately following the Memorandum? Describe the circumstances under which you became aware of these notes.

(3) At the time you became aware of the " Moore notes", did you or any licensee personnel read the portion of the notes which indicate 1

that Mr. Moore was informed on March 28, 1979 that in-core thermo-couple temperatures read over 2500 degrees F?

Identify all persons who are aware that Mr. Moore had taken notes on March 28, 1979 which indicated he was so informed, and the dates these persons learned that fact.

(4) Identify any discussion with GPU personnel or attorneys concerning l

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LPage Two

. Trowgridge Letttr.

September _24,1984

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whether' these 'in-core temperature readings indicated thepossible generation of hydrogen? Identify any discussions with GPU personnel or, attorneys concerning whether these in-core temperature readings indicated severe core damage.

-In answering these questions identify all persons who participated in any such discussions and the substance and nature of each such Jperson's participation.

(5) Identify any GPU personnel or attorney who concluded or determined that. Mr. Moore or other GPU or B&W personnel concluded on March 28, 1979, that in-core temperatures in excess of 2500 degrees F indicated the generation of hydrogen. -

,. (6) Identify.any GPU personnel or attorney who determined that Mr.

Moore or any other GPU or B&W personnel concluded on March 28, 1979, that _in-core temperatures in excess of 2500 degrees F indicated severe core damage.

-(7) Identify any discussions or conversations concerning whether the information contained in these notes, that is, that Mr. Moore knew on -

U March 28, 1979 that in-core thermocouples had read temperatures exceeding 2500 degrees F, should have been reported to the NRC. If any such discussions or_ conversations are identified, state with respect to each such discussion or conversation the following:

(a) the persons participating in any such discussion or

, conversation; (b)- -the date of all such discussions or conversations; and (c) any action- taken by licensee persor.nel as a result of

, s any such discussion or conversation;

.(8) ' Identify all- persons to whom the " Moore notes" were distributed and the date and purpose for such distribution.

(9) Identify any discussions or conversations concerning the " Moore

. notes" between you and any of the following individuals

.

(a) Robert Arnold; (b) E.G. Wallace;-

(c) B. Behrle; (d) Herman Dieckamp; and (e) the NRC Staff or any NRC Commissioner.

(10) When did you become aware of the " Untitled Memorandum" written by Mr. Behrle, Mr. Guilbord and Mr. Reppert, which is a second attach-ment to the Arnold Memorandum? Describe the circumstances under which

Page Three Trowbridge Letter

-September 24. 1984-2 you first became aware of this Memorandum.

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.( 11) What is' your understanding of the purpose or reason the September

'17,1980, Arnold Memorandum wa:. prepared for Mr. Arnold? How has GPU used this Memorandum since its preparation?

, -(12) .:When did you first become aware of the draft TDR-115 which appears

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asithe last attachment to the Memorandum to Mr. Arnold? Describe the.

circumstances' under which you first.became aware of the draft TDR-115.

-(13) If you did not , learn of the September 17,1980,' Memorandum.to L Mr. Arnold at or near~the date of its preparation, explain why you did not receive.a copy although you are listed'on the distribution for the Memorandum.

_ (14) ' Describe your' understanding of the . reason (s) that Mr. Arnold t' '

. requested information from Mr. Wallace concerning " Internal Work

,s Related to GPU's Knowledge of-Core Damage Following the TMI-2 Accident" at' or.near the date of the Memorandum. Include in your response whether -

-one of the reasons Mr. Arnold requested such a memorandum was the on-

- going NRC . investigation into the reporting of information during the

-accident.

< (15) . To.your. knowledge, to whom was the information contained in

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-Mr. Moore's notes distributed on. March 28, 1979? . Include-in your response any knowledge or information of distribution of such informa-tion to Mr. Arnold, Mr. Dieckamp, Mr. Wallace~, or Mr. Keaton.

h '(16)~ Describe any conversations, discussions or other communications with Mr. Moore concerning the substance of his notes, in particular

'the notation in his notes that he learned that in-core thermocouple readings indicated .tempe.atures .in excess of 2500 degrees F on March

- 28, 1979.

(17) Describe the' GPU position on the date you learned of Mr. Moore's notes, with regard to the individuals who knew or learned on March 28, 1979 of any of the following:

(a) . hydrogen had been. generated due to the zirconium-steam-

~

, reaction; (b) a. hydrogen combustion and/or explosion had occurred, or.-

. some type of explosion had occurred;

.(c) the core had been severely damaged,

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(d) .in-core temperatures:in excess of 2200 degrees F had been measured; f

s .(e) in-core temperatures in excess of 2200 degrees F had been measured and were believed to be accurate by some GPU personnel .

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Page Fcur Trowbridge Letter September 24,1984 1

(6) Describe any' communications, discussions or conversations with Mr. Dieckamp concerning whether Mr. Mehler or Mr. Chwastyk's inter-views cited in question (1) above constituted evidence that some persons at TMI-2 on March 28, 1979, interpreted the pressure spike

.in terms of hydrogen generation on that day.

Answer the. question above with regard to any communications, discussions or conversations with Mr. Dieckamp concerning whether Mr. Mehler or Mr. Chwastyk's interviews constituted evidence that some persons on March 28, 1979, interpreted the pressure spike in terms of core damage.

(7) Describe any communications, discussions or conversations with any GPU personnel, including Mr. Dieckamp, as to whether any state-ments Mr. Dieckamp made in his mailgram should be corrected, amended or otherwise modified. For any such communications, discussions, or conversations identified above, state the following:

(a) the date it occurred; (b) all participants; and (c) any action licensee took as a result of any such conversation, discussion, or communication.

I understand from my conversation with you Friday that you believe Mr.

Blake will be willing to answer questions about these two issues as long as they request factual information. Therefore, I have attempted through '

these questions to request factual information.

As you know, Mr. Blake is currently noticed for a deposition to commence on September 27, 1984. 'I hope that your offer to provide written answers to our questions where appropriate will eliminate the need for his deposition.- 'Therefore, I ask you to contact me as- soon as possible as to whether he will answer these written questions. I will be in Harrisburg from Tuesday morning through Friday for other scheduled depositions.

If we cannot reach some agreement on Mr. Blake's response to the questions posed above, we will have to proceed with Mr. Blake's deposition on_ Thursday. In the alternative, we will have to determine a mutually convenient date to which to continue the deposition.

Please contact me at your earliest possible opportunity.

Sincerely yours, r\

W 24wJA Lyn Bernabei cc: Service List b

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