ML20209A657

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Inquiry Into TMI-2 Leak Rate Data Falsification,Docket Number Lrp.* Confirms 870121 Telcon W/Aamodt Following Telcon W/Judge Kelley Re Modifying ASLB Order to Provide for in-hand Svc on 870202 W/Overnight Delivery to Other Parties
ML20209A657
Person / Time
Site: Crane 
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-#187-2354 LRP, NUDOCS 8702030410
Download: ML20209A657 (2)


Text

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LEBOEU F, LAM B, LEl BY & MAc RAE uat i L.

A PARTNERSMip INCLUDING PROFES$10NAL CORPORATIONS (;hly 13 33 N EW H A M PS H I R E AV EN U E, N. W.

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,,o SALT LAM E CITY. U T 3 g j, N.

SOUTH PORT, CT AL B AN Y. N Y RALEIO M, N C SAN FR ANCISCO. CA N EWAR M, NJ

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January 23, 1987 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:

This is to confirm a telephone conversation with Mrs.

Aamodt of today, following my telephone conversation with i

Judge Kelley on Wednesday, January 21, 1987.

In our January 21 conversation, I explained to Judge Kelley that the requirement in the Board's January 21 order of in-hand delivery on February 2, 1987 on parties out of the Washington, D.C.

area would be a matter of great difficulty and expense because February 2 is a Monday, and courier I

services typically do not pick up packages on Sundays.

i Accordingly, I suggested that the Board modify its order to provide for in-hand service on the Board on February 2, with overnight delivery to the other parties, so that the other parties would receive the remaining proposed findings of the Numerous Employees and the proposed findings of the Aamodts on February 3, 1987.

8702030410 870123 PDR ADOCK 05000320 3 Sc3 G

PDR

e Judge Kelley stated that my request was acceptable to the Board, but asked that I attempt to agree with Mrs. Aamodt on the matter and, if successful, confirm that understanding in a letter to the Board.

Mrs. Aamodt and I spoke today, and agreed to the following:

each of our February 2 filings will be in the Board's hands by February 2.

We will each serve the other parties on that date by hand delivery or by overnight delivery (either Federal Express or Express Mail).

In addition, I will send the Aamodts, by Express Mail to a Parkesburg, Pa. post office address, an extra copy of our February 2 filing, while also sending a copy by Express Mail to the Aamodts' Lake Placid post office box.

The agreement to send an extra copy of our February 2 filing to Parkersburg is a courtesy, does not apply to any other filing, and does not apply to any other party.

I also told Judge Kelley that I would contact the other parties by telephone to be certain that they had no objection to this modification of the Board's January 21, 1987 order.

I spoke with Messrs. Blake and Burns and with Ms. Hensley, and each of them agreed that receipt by February 3 of the February 2 filings of the Aamodts and the Numerous Employees would suffice.

Because he is in the Washington, D.C.

area, we will nevertheless serve Mr. Blake by hand on that date.

Mrs. Aamodt indicated that she would probably serve Mr.

Gephart by hand on February 2, because she expects to be in Harrisburg on that date.

In the interest of clarity, I should add that Judge Kelley indicated to me that these arrangements do not modify the requirement in the Board's January 21 order that all parties' reply findings must be in the Board's and other parties hands on February 17, 1987.

I trust these arrangements are satisfactory to the Board.

We appreciate your willingness to accomodate us due to logistical difficulties.

Very truly yours, Michael F. McBride Attorney for the Numerous Employeas cc:

All Parties Smith B. Gephart, Esq.

Mary Wagner, Esq.