ML20107A940

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Notice to ASLB of Licensee Consideration to File Supplemental Testimony,In Nature of Rebuttal,In Response to Ucs case-in-chief.Svc List Encl.Related Correspondence
ML20107A940
Person / Time
Site: Crane Constellation icon.png
Issue date: 10/29/1984
From: Bauser D
GENERAL PUBLIC UTILITIES CORP.
To:
References
CON-#484-855 SP, NUDOCS 8411020031
Download: ML20107A940 (4)


Text

,oYO October 29, 1984 h/(,5[O 04 hDy -f g0:17 UNITED STATES OF AMERICA NUCLEAR REGULATORY COr4 MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'E

, -[,5 h.

a

,.,g In the Matter of

)

)

50-2895df' METROPOLITAN EDISON COMPANY

)

Docket No.

)

(Restart Remand on

)

Management)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

NOTICE TO THE BOARD OF LICENSEE'S CONSIDERATION OF THE NEED TO FILE REBUTTAL TESTIMONY On Monday, October 22, 1984, the Union of Concerned Scien-tists (UCS) identified to Licensee its intention to call Dr. James Regan as an expert witness on the remanded issue of training.

Over the course of last week, UCS took the deposi-tions of seven Licensee witnesses.

Based on the identification of Dr. Regan as UCS' expert witness, and the lines of ques-tioning pursued by UCS during the recent depositions, it is possible that Licensee may seek the Board's permission to file supplemental testimony, in the nature of rebuttal, in response to UCS' case-in-chief.

Licensee is aware of the fact that the NRC rules of prac-tice specifically provide for the submission of rebuttal testi-mony.

10 C.F.R.

S 2.743(a);

see, e.g..

Philadelphia Electric Company et al.

(Peach Bottom Atomic Power Station, Units 2 and 3), ALAB-566, 10 N.R.C. 527, 529, 530 and n.4 (1979).

However, 8411020031 841029 PDR ADOCK 05000289 Q

PDR bd

m T

rather than waiting until after Dr. Regan is deposed or until Dr. Regan's testimony is filed, both of which are scheduled for November 13, counsel for Licensee informed UCS last Friday, October 26, that Licensee was considering filing such supple-mental testimony, and today informed Staff counsel of this fact.

Licensee thought it would be prudent to inform the Board, as well, of our consideration of this possibility, not-withstanding the fact that Licensee is not now in a position to state with certainty whether such rebuttal testimony will be offered.

In any event, it is our intention, should such testi-many be necessary, to file prefiled testimony which would be available to the Board and to the parties with sufficient time to prepare for cross-examination of the witness (es).

Respectfully submitted, b4dvwLk Deborah B.

Bauser Dated:

October 29, 1984 cc:

Service List __

1 N..

k I

UNITED STATES OF AMERICA NUCI. EAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter

)

)

METROPOLITAN EDISON COMPANY

)

Docket No. 50-289 SP

)

(Restart Romand on Management)

I (Three Mile Island Nuclear

)

i Station, Unit No. 1)

)

SERVICE LIST I

Nunzio J. Pal adano, Chairman Administrative Judge U.S. Nuclear Fegulatory Commission John H.

Buck Washington, 0.0.

20555 Atomic Safety & Licensing Appeal Board Thomas M.

Roberts, Commissioner U.S. Nuclear Regulatory Commissi:

U. P.. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge James K. Asselstine, Commissioner Christine N. Kohl l

U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal l

Washington,

D.C.

20555 Board U.S. Nuclear Regulatory C miss:

Frederick Sernthal, Commissioner Washington, D.C.

20555 U.S. Nuclear. Regulatory Commission Washington, D.C.

20555 Administrative Judge Ivan W.

Smith, Chairman Lando W.

Zech Jr., Commissioner Atomic Safety & Licensing Soard U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissb 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 Commissa U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555

. ~

i Administrative Judge Mr. Henry D. Mukill Gustave A. Linenberger, Jr.

Vice President Atomic Safety & Licensing Scard, GPU Nuclear Corporation c.s. Ihaclear negulatory 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 & Licer. sing Board TMI ALgRT 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 Instituto Soard Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.

20002 Washington, D.C.

20555 Lynne Bernabei, Esq.

G vernment Acc untability Jack R.

Goldberg, Esq. (4)

  • C Office of tne Executive Legal

,g{0 onnecticut Avenue Washington, D.C.

20036 U.S uc1 ar Regulatory Commission Washington, 0.C.

20555 Ellyn R. Weiss, Esq.

3arron, Weiss & Jordan Thomas Y.

A;, Esq.

2001 S Street, N.W.,

Suite 43-Office of Chief Counsel Washington, D.C.

20003 Department Of Environmental Resources Michael F. McBride, Esq.

505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.-

Harrisburg, PA 17120 Suite 1100 Washington, D.C.

20036 Michael W.

Maupin, Esq.

Hunten & Williams 707 East Main Street P.O.

Box 1535 Richmond, VA 23212 William T.

Russell Deputy Director, Division of Human Factors Safety Office of NRR Mail Stop AR5200 U.S.

Nuclear Regulatory Commission Washington, D.C.

20555

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