ML20098F396
| ML20098F396 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/01/1984 |
| From: | Trowbridge G GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| CON-#484-209 SP, NUDOCS 8410020708 | |
| Download: ML20098F396 (7) | |
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RELATED COP.RESPONDENCE 00CKETED USNRC October 1, 1984 14 0CT -2 #1 :2:4 UNITED STATES OF AMERICAriCE OF EPtw NUCLEARREGULATORYCOMMId51dNjy' L#VI '
Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Three Mile Island Nuclear
)
(Restart Remand on Management)
Station, Unit No. 1)
)
LICENSEE'S FIFTH SET OF INTERROGATORIES TO INTERVENOR THREE MILE ISLAND ALERT, INC.
These interrogatories are directed to Intervenor Three Mile Island Alert, Inc. (hereinafter TMIA) and pertain to the reopened hearing on the Dieckamp mailgram.
See Metropolitan Edison Co. (Three Mile Island Nuclear Generating Station, Unit 1), ALAB-772, 19 N.R.C.
slip op. at 128-134 (May 24, 1984).
See also Memorandum and Order Following Prehearing Con-ference (July 9, 1984).
The interrogatories are filed pursuant to 10 C.F.R. 5 2.740b, which requires that they be answered separately and fully in writing under oath or affirmation, within 14 days after service.
The interrogatories are intended to be continu-ing in nature, and the answers must be immediately supplemented or amended, as appropriate, should TMIA obtain any new or differing information responsive to the interrogatories.
8410020708 841001 PDR ADOCK 05000289 G
W Licensee asks these. interrogatories of TMIA in its capaci-ty as lead intervenor on the issue of the Dieckamp mailgram.
Licensee assumes that TMIA's response will reflect the collec-tive knowladge of any intervenor who has an interest in, or de-sires to participate on, this issue.
If Licensee is incorrect in its assumption, TMIA should promptly inform 7 a.nsee so that appropriate discovery requests can be provided to other inter-venors as well.
A.
Instructions Any reference to Intervenor Three Mile Island Alert, Inc.-
(TMIA) shall be deemed to include all members of TMIA, and any other intervenor and its members on whose behalf TMIA is act-ing.
When knowledge or information of TMIA is requested, such request includes knowledge or information of TMIA's members, employees, consultants, and unless privileged, its attorneys, and also includes the information of any other intervenor on whose behalf TMIA is acting and such intervenor's members, em-ployees, consultants, or attorneys.
When identification of a document is requested, briefly describe the document (i.e., letter, memorandum, book, pam-phlet, etc.) and state the following information as applicable to the particular document:
name, title, number, author, date of publication and publisher, addressee, date written or ap-proved, and the name and address of the person (s) having pos-session of the document.
With respect to any interview or !
l
_________________________________________________j
V deposition, state in addition to the information requested above the name and affiliation of the interviewer or deposer, and the date of the interview or deposition.
With respect to any testimony, state in addition to the information requested above before whom and on what date the testimony'was given.
The following definitions apply to each of the interroga-tories:
1.
" Document" means all writings and records of every type, including, but not limited to, memoranda, correspondence, re-ports, surveys, tabulations,-maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind.
" Document" shall also mean every copy of a document when such copy is not an identical duplicate of the original.
2.
" Pressure spike" means the increase in the containment pressure that occurred at Three Mile Island, Unit 2, at approx-imately 1:50 p.m. on March 28, 1979, or the corresponding re-cordings on any strip recoi ar or other instrument, or the cor-responding actuation of any alarm.
3.
" Spray initiation" means the activation of containment sprays at Three Mile Island Unit 2 at approximately 1:50 p.m.
on March 28, 1979.
B.
Interrogatories 1.
During the Prehearing Conference of September 17, 1984, TMIA indicated that Dr. Henry Myers had conducted some,
c
v investigations of his own.
Tr 27400.
Dr. Myers is the princi-pal author of the Report Prepared by the Majority Staff of the House Committee on Interior and Insular Affairs, " Reporting of Information Concerning the Accident at Three Mile Island" (March 1981).
a.
Identify any investigations that relate to the subject matter of the remanded hearing and that Dr. Myers con-ducted himself.
b.
Identify any persons interviewed or deposed by Dr.
Myers during the course of such investigation, the date on which such interview or deposition occurred, and the informa-tion that Dr. Myers obtained.
c.
Identify any document which refers to or memorial-izes such investigations.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE u
mb6 Gb6rge Tre@ ridge,P[.
David Lewis Counsel for Licensee Dated: October 1, 1984 l
I l,
Y OctobGr 1, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart Remand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Fifth Set of Interrogatories to Intervenor Three Mile Island Alert, Inc."
were served this 1st day of October, 1984, by hand delivery to the parties identified with an asterisk and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
David R.
Lewis i
Dated: October 1, 1984 d
1 q
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter
)
)
1 METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP j
)
(Restart Romand on Management)
(Three Mile Island Nuclear
)
)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J.
Palladino, Chairman Administrative Judge 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 Commissic.-
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 i
. ashington, D.C.
20555 W
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d 2-
'i -
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.
Jack R.
Goldberg, Esq. (4)
G vernment Accountability Office of the Executive Legal 15 5 C nnecticut Avenue U.S Nuc ear Regulatory Commission Washington, D.C. 20036 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 William T.
Russell Deputy Director, Division Michael W.
Maupin, Esq.
of Human Factors Safety Hunton & Williams Of fice of NRR 707 East Main Street Mail Stop AR5200 P.O. Box 1535 U.S. Nuclear Regulatory Richmond, VA 23212 Commission Washington, D.C.
20555 w
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