ML20207Q275

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Inquiry Into TMI-2 Leak Rate Data Falsification.* Vol 1 of Proposed Findings of Fact & Conclusions of Law of Numerous Employees & Memorandum of Law Encl.W/O Encls
ML20207Q275
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/23/1987
From: Mcbride M
GENERAL PUBLIC UTILITIES CORP., LEBOEUF, LAMB, LEIBY & MACRAE
To: Bright G, Carpenter J, Kelley J
Atomic Safety and Licensing Board Panel
References
CON-#187-2284 LRP, NUDOCS 8701270114
Download: ML20207Q275 (2)


Text

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, LEBOEUF, LAMB, LElBY & MACRAE

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. SOUTMRONT, CT g 7 CALEIGM,NC ]",,,i NEWARM,NJ S AN FR ANCISCO, C A EDISON,NJ LOS ANG ELES. C A J ACMSONvs LLE, FL January 23, 1987 HAND DELIVERY Judge James L. Kelley Judge Glenn O. Bright Chairman Atomic Safety and Atomic Safety and Licensing Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Judge James H. Carpenter Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Inquiry Into Three Mile Island Unit 2 Leak Rate Data Falsification, Docket No. LRP

Dear Sirs:

Enclosed in accordance with the Board's order of November 12, 1986 (Tr. 5324) are four copies of Volume One of the " Proposed Findings of Fact and Conclusions of Law of the Numerous Employees", including an extra copy for the Board's convenience. Volume One includes all of our proposd findings on the technical issues. Volume Two, including individual findings, will be filed on or before February 2,1987.

For the Board's convenience, we have also included in our proposed findings four Appendices, the first of which list the Exhibits herein, the second of which provides corresponding Stier and NRR leak rate test numbers, the third of which is a copy of the indictment of Metropolitan Edison Company, and the fourth of which includes certain pages from the Transcript of Met Ed's change of plea and sentencing. The Board can take official notice of the materials in Appendices C and D, because the Commission did so in its order establishing this proceeding. CLI-85-18, 22 N.R.C. 877 (1985).

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s Nuclear Regulatory Commission January 23, 1987 Page 2 Also enclosed are four copies of a Memorandum of Law which addresses certain legal issues that are raised by this proceeding.

At Transcript pages 5334-38, the Board asked the parties to address three questions: (1) the problem of correlating " strip chart time" versus "real time"; (2 )

whether water additions that may have occurred during leak rate tests were necessary for operational reasons; and (3) whether hydrogen additions that may have occurred during leak rate tests were necessary for operational reasons. Our proposed findings and conclusions address those three questions. The first question is specifically addressed in 11 282-86; the second question is specifically addressed in 11 292-305 and 311-14; and the third question is specifically addressed in 11 306-10. Each of those questions is also addressed more generally throughout Section IV.F (11 237-314) and will also be addressed in certain of the individual findings.

Very truly yours, Michael F. McBride Attorney for the Numerous Employees cc (w/ encl . ) : Service List l

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