ML20205F664

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Confirms Recent Telcon Clarifying Points Re Discovery Responses.Nrc Will Suppl Prior Response If Addl Documents Found in Response to Discovery Request That NRC Objected to & Answered.Svc List Encl.Related Correspondence
ML20205F664
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/20/1987
From: Doris Lewis
GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Dante Johnson, Johnson G
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#187-2919 CIV-PEN, EA-84-137, NUDOCS 8703310243
Download: ML20205F664 (2)


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March 20, 1987 1

George Johnson, Esquire Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 In the Matter of GPU K1 clear Corporation (Three Mile Island Nuclear Station, Unit 2 Docket No. 50-320 -- EA 84-137-010 PE4 Dear Georges This letter is to confirm our telephone conversation Wednesday on several matters to clarify some points concerning the discovery responses.

First, in those instances where the NRC staff objected to one of GPUN's discovery requests but neverthe-less provided a further response identifying or producing docu-ments "without waiving the objection," you have advised the re-sponse was complete (i.e.

despite the objection, all responsive documents were identiTied,or produced).

In addition, you agreed that if the NRC discovers additional documents responsive to a discovery request to which the NRC has objected but nevertheless answered, the NRC will supplement its prior response.

We of course will follow the same procedure.

Second, you confirmed that the NRC's search for interview notes was not limited to interviews of Parks but encompassed in-terviews of any other person pertaining to any of Parks' allega-tions.

You indicated that all such notes of which the NRC is aware have been identified and made available to GPUN.

Sincerely, A.

0703310243 070320

{DR ADOCK 05000320 David R. Lewis PDR Counsel for GPUN cc:

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Administrative Law Judge In the Matter of

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GPU Nuclear Corporation

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Docket No. 50-320

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License No. DPR-73

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EA-84-137 (Three Mile Island Nuclear

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Station, Unit No. 2)

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SERVICE LIST

'Ivan Smith, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docketing and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555 George E. Johnson, Esquire Office of the General Counsel 9604 MNBB U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dated:

March 20, 1987