ML20099C544
| ML20099C544 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/09/1984 |
| From: | Doris Lewis METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20099C539 | List: |
| References | |
| SP, NUDOCS 8411190580 | |
| Download: ML20099C544 (9) | |
Text
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'o f[$kkESber9, 1984 34 novis man 2, UNITED STATES OF AMERICA r,r g
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NUCLEAR REGULATORY COMMISSION g$p-]:f i
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Before the Atomic Safety and Licensing Board In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
)
(Restart Remand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
LICENSEE'S FIRST SUPPLEMENTAL RESPONSE TO THREE MILE ISLAND ALERT'S FOURTH SET OF INTERROGATORIES In response to TMIA's Interrogatory No. 3 of its Fourth Set of Interrogatories, Licensee stated that T.
Gary Broughton left for TMI about noon and shortly after his arrival at TMI went to dinner.
Licensee's Answers to Intervenor Three Mile Island Alert's Fourth Set of Interrogatories to General Public Utilities (Oct.
9, 1984) at 7-8.
Upon further reflection dur-ing and after his recent deposition, Mr. Broughton believes that he may have left somewhat later, possibly between 1:30 and 8411190500 841109 PDR ADOCK 05000289 g
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He is also unsure if he ate dinner before or after his arrival at the observation center'.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE L u.c.
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Ernest L.
Blake, Jr.,
P.C.
David R.
Lewis Counsel for Licensee Dated:
November 9, 1984 l
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h November 9, 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 First Supple-mental Response to Three Mile Island Alert's Fourth Set of In-terrogatories," dated November 9, 1984, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk
(*) by hand delivery, this 9th day of November, 1984.
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David R.
Lewis Dated: November 9, 1984
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i UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter
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)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart Remand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
}
SERVICE LIST l
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 Commissi:r 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.
Frederick Bernehal, Commissioner Nuclear Regulatory Commissior 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 Commissi:n 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 l
Board U.S. Nuclear Regulatory Commiss; n U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
e.
Administrative Judge Mr. Henry D.
Mukill 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.
l Jack R.
Goldberg, ssq. (4)
Government Accountability Office of the Executive Legal Project Director 1555 Connecticut Avenue U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C.
20555 Ellyn,R. Weiss, q.
Harmen, 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 1I33 New Hampshire Avenue, N.W.
Harrisburg, PA 17120 Suite 1100 Washington, D.C.
20036 William T.
Russell Depury Director, Division Michael W.
Maupin, Esq.
of Human Factors Safety Hunton & Williams Office 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 l
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1 UNITED STATES OF AMERICA NUCLEAR REGULA1 DRY CG NISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
MEIROPOLITAN EDISON COMPANY
)
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)
Docket No.50-289SP
)
(Restart - Remand on Mgt.)
)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
AFFIDAVIT OF J. R. THORPE State of New Jersey
)
County of Morris
)
ss.
J. R. Thorpe, being duly sworn according to law, deposes and says that he is the Director - Licensing and Regulatory Affairs of GPU Nuclear Corporation, that information contained in Licensee's Response to Three Mile Island Alert's Fourth Set of Interrogatories, numbers 3(a) - except 3(a)(g), 4, 5, 6, 20, and 21 is true and correct to the best of his knowledge and belief.
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J. R. Thorpe Director - Licensing and Regulatory Affairs Sworn to and subscribed before me this 2 day of November, 1984 s
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AOCE 3. house Notary Public MOTW PUBUC OF MEW JERSET W Ccmmission Expires Earrh 7.1985 My Commission Expires:
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UNITED STATES OF AMERICA NUCLEAR REGUIAIDRY CGMISSION Before the Atomic Safety and Licensing Board j
In the Matter of
)
)
h METROPOLITAN EDISON COMPANY
)
(
)
Docket No.50-289SP
)
(Restart - Remand on Mgt.)
)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
AFFIDAVIT OF T. G. BROUGHTON State of New Jersey
)
County of Morris
)
ss.
T. G. Broughton being duly sworn according to law, deposes and says that he is the Director - Systems Engineering of GPU Nuclear Corporation, that information contained in Licensee's Response to Three Mile Island Alert's Fourth Set of Interrogatories as modified by Licensee's First Supplemental Response to Three Mile Island Alert's Fourth Set of Interrogatories ntsnber 3 (a) (g) is true and correct to the best of his knowledge and belief.
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.s 1 :. s T. G. Broughton Director - Systems Engineering Sworn to and subscribed before me this A day of &AoM
, 1984, id b
Notary Public
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My Commission Expires:
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UNITED STATES OF AMERICA NUCLEAR REGUTA1 DRY CO> MISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
)
METROPOLITAN EDISON COMPANY
)
)
Docket Nc.50-289SP
)
(Restart - Remand on Mgt.)
(Three Mile Island Nuclear
)
Station, Unit No. 1
)
AFFIDAVIT OF H. M. DIECKAMP State of New Jersey
)
County of Morris
)
ss.
H. M. Dieckamp, being duly sworn according to law, deposes and says that he is the President, GPU Service Corporation and on March 28, 1979 he was President, GPU Service Corporation, that the information contained in Licensee's Response to Three Mile Island Alert's Fourth Set of Interrogatories, ntabers 16, 17, 18, and 19 are true and correct to the best of is knowledge and belief.
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H. M. Dieckamp
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President GPU Service Corporation Sworn to and subscribed before me this /d day of October, 1984 ll CO2
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Notary Public q.,,,
i - G E Notyy en sr Nm Jersey My Cer,mnson Oo.res June 6,1988 My Commission Expires:
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UNITED STATES OF MERICA NUCLEAR REGUIATORY CGNISSION i
Before the Atomic Safety and Licensing Board j
In the Matter of
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)
t
)
Mi11t0POLITAN EDIS(M (INPANY
)
)
Docket No.50-289SP
)
(Restart - Remand on Mgt.)
(Three Mile Island Nuclear
)
Station, Unit No. 1
)
AFFIDAVIT OF R. J. CHISHOIM State of New Jersey
)
County of Morris
)
ss.
R. J. Chisholm, being duly sworn according to law, deposes and says that he is the Manager, Electrical Power and Instrumentation - GPU Nuclear Corporation, that the infomation contained in Licensee's Response to Three Mile Island Alert's Fourth Set of Interrogatories, numbers 14 and 15 are true and correct to the best of his knowledge and belief.
R. J. Citisholm Manager, Electrical Power and Instrumentation Sworn to and subscribed before me this /7-day of October, 1984 Notary Public t:
F C' My Commission Expires:
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