ML20155F615
| ML20155F615 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/18/1986 |
| From: | Maupin M HUNTON & WILLIAMS, MILLER, G.P. |
| To: | |
| References | |
| CON-#286-853 LRP, NUDOCS 8604220280 | |
| Download: ML20155F615 (6) | |
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RELATED COR6 J
s t%F April 18, 1986 B7 AR7 21 gg;g, UNITED STATES OF AMERIC h k NUCLEAR REGULATORY COMMISSIOff SMf o' '
Before the Presiding Board In the Matter of
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) Docket No. LRP INQUIRY INTO THREE MILE ISLAND
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g gg UNIT 2 LEAK RATE DATA FALSIFICATION )
RESPONSE OF GARY P. MILLER TO LIST OF PROPOSED TECHNICAL WITNESSES AND LIST OF DOCUMENTS PROPOSED FOR THE INITIAL RECORD SET FORTH IN MEMORANDUM AND ORDER OF MARCH 26, 1986 By its Memorandum and Order of March 26, 1986, the Presiding Board requested that any objections or suggested additions the parties may have to Items 1 through 3 of its List of Proposed Board Witnesses and to its List of Documents Proposed for the Initial Record be filed by April 18, 1986.
Memorandum and Order of March 26, 1986 at 10.
Mr. Miller has no objections or suggested additions to Items 1 through 3 of the Presiding Board's 8604220280 860418 PDR ADOCK 05000320 G
PDR 3s03
s m - t List of Proposed Board Witnesses set forth in Attach-ment A to the March 26, 1986 Memorandum and Order.1 Mr. Miller has no objections or suggested additions to the publicly available documents contained in the Board's List of Documents Proposed for the i
Initial Record, set forth in Attachment B to the March l
26, 1986 Memorandum and Order.
Since Mr. Miller has i
1 not had an opportunity to revieu the proposed documents that have yet to be released to the public, he reserves the right to object and suggest additions to those documents.2 1The list of technical witnesses is, at this time, limited to Jared S. Wermeil, Donald C.
Kirkpatrick, Winthrop A.
Rockwell and Edwin H.
Stier.
The documents that have not yet been released to the public are:
(1) Memorandum from Victor Stello, Jr., Acting Executive Director of Operations, to Commissioners, March __, 1986:
Results of NRR's Investigation and Evaluation of Ten Licensed Operators l
Involved in TMI-2 Preaccident Leak Rate Testing Irregularities, including attachments and supporting documents; (2) Office of Investigations Report of Investigation Leak Rate Falsifications, including all attachments; (3) Memorandum from William T. Russell to Harold R.
Denton, September 20, 1985:
Stier Report on TMI-2 Leak Rate Testing
Respectfully submitted, GARY P. MILLER By Michael W. Maupin, CounseT Of Counsel Michael W. Maupin j
Maria C. Hensley HUNTON & WILLIAMS P.O.
Box 1535 Richmond, Virginia 23212 bated:
April 18, 1986 I,
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April 18, 1986 l
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.l Before the Presiding Eoar'd In the Matter of
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) Docket No.'LRP INQUIRY INTO THREE MILE ISLAND
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UNIT 2 LEAK RATE DATA FALSIFICATION )
CERTIFICATE OF SERVICE i
l I certify that copies of the Response of Gary P.
j.
Miller to List of Proposed Technical Witnesses and List of Documents Proposed for the Initial Record Set Forth in Memorandum and Order of March 26, 1986, dated l
April 18, 1986, were served upon the following persons 4
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by deposit in the U.S. Mail, first class, postage pre-paid:
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Secretary U.S. Nuclear Regulatory Commission l-Washington, D.C.
20555 ATTENTION:
Chief, Docketing and Service Section 4
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4-Administrative Judge James L. Kelley, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Glenn O. Bright Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Jerry R.
Kline Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Ernest L. Blake, Jr., Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Jack R.
Goldberg, Esq.
Office of the Executive Legal Directors U.S.
Nuclear Regulatory Com:aission Washington, D.C.
20555 Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Suite 1100 Washington, D.C. 20036 Smith B.
Gephart, Esq.
Killian & Gephart 216-218 Pine Street P.O. Box 886 Harrisburg, Pennsylvania 17108
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1 James B.
Burns, Esq.
Isham, Lincoln & Beale 3 First National Plaza i
Suite 5200 Chicago, Illinois 60602 l
j Ms. Marjorie M. Aamodt j.
Mr. Norman O. Aamodt Box 652 Lake Placid, New York 12946 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1
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Michael W. Maupin 4
Counsel for Gary P. Miller Dated:
April 18, 1986 i
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