ML20211F533

Gpu Nuclear Corp Response to NRC Second Set of Interrogatories.* Persons Attending 830323 Meeting Re R Parks Public Statement Listed.Certificate of Svc Encl. Related Correspondence

ML20211F533
Person / Time
Site:	Three Mile Island
Issue date:	02/19/1987
From:	Doris Lewis GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
CON-#187-2579 CIV-PEN, EA-84-137, NUDOCS 8702250123
Download: ML20211F533 (4)

Text

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El $$ }'S 1 v.w ygcoaaewuj s N g DCR E TET uvWC February 19, 1987

'87 FEB 24 P2 :04 UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION g; -

Before the Administrative Law Judoe .' >

In the Matter of )

GPU Nuclear Corporation ) Docket No. 50-320-etvPEM

) EA-84-137 (Three Mile Island Nuclear )

Station, Unit No. 2) )

GPU NUCLEAR CORPORATION'S RESPONSE TO NRC STAFF'S SECOND SET OF INTERROGATORIES On January 29, 1987, the NRC Staff filed NRC Staff's Second ,

Set of Interrogatories and Request for Documents to GPU Nuclear...

Corporation (GPUN). GPUN provides the following responses to the interrogatories. Persons who have provided information on which these responses are based are indicated parenthetically at the end of each response.

Interrogatory 1: Provide a list of all persons who attended a meeting held at the TMI-2 site on the morning of March 23, 1983, concernino a oublic statement made by Richard Parks, Robert Arnold, Bahman Kanga, John Barton, Douglas Bedell, James Larson, M. Ken Pastor, Henry D. Hukill, Blaine Ballard, John C.

DeVine, Edwin Gischel and James E. Hildebrand attended the meet-ing. William Gifford, James Thiesing, Joseph Chwastyk, Ron Freemerman, George Kunder, David R. Buchanan, David M. Lake, James J. Byrne, R. H. Fillnow, Larry G. Santee, Richard E.

0702250123 B70219 PDH ADOCK 05000320 g VDR f~

t Sieglitz, and Robert P. Metzger may also have attended the meet-ing. There may'have been other attendees whose presence is no longer recalled 5 (Stier, Arnold, Kanga)

Interrogatory 2: Provide the names of persons sitting at the table in the room where the meetina described above was held.

Edwin Gischel stated in his January 15, 1987 deposition at page 69 that Robert Arnold, Bahman Kanga, John Barton, Gischel, and others were seated at a table. Mr. Arnold recalls that he, Mr.

Kanga, and Mr. Barton were seated alone at a table which, if not the only table in the room, was separated from any other tables.

GPUN has no record of who was seated at tables at the meeting. _',

(Stier, Arnold, Gischel) --

Interrogatory 3: Identify any GPUN or Bechtel Corporation person-nel in addit:,on to Edward J. Kitler, who heard, during the period January 1, 1983 to March 21, 1983, Thomas E. Morris, a Bechtel Corporation employee, state words to the effect that Richard D.

Parks should be transferred from the TMI-2 site, or otherwise removed from his responsibilities on the TMI-2 site.

GPUN is unaware of any such GPUN or Bechtel Corporation person-nel.

Interrogatory 4: Identify any such oral communications referred to in Interrogatory 3, including all information requested in the

" Instructions and Definitions" enumerated above.

Information responsive to this interrogatory is contained in the January 13, 1987 deposition of Edward J. Kitler at pages 65, 69, and in the February 10, 1987 deposition of Thomas E. Morris at pages 38-42, 47-48, which describe a conversation sometime after January 20, 1983. Mr. Morris states at page 49 of his deposition that ne had no "further conversation with Mr. Kitler about Parks.

(Kitler, Morris)

].

Interrogatory 5: Identify any oral or written comunications be-tween January 1, 1983 and March 21, 1983, otherwise not identi-

fled above, involving one or more GPUN or Bechtel employees on

! the TMI-2 site, or elsewhere, in which the transfer of Richard Parks or the removal of Mr. Parks from his responsibilities at which the TMI-2 site was discussed.

A conversation between Richard Parks and Edward Kitler on j February 18, 1983 is described in the January 13, 1987 deposition of Edward Kitler at pages 66-67.

I (Kitler) '.

Respectfully submitted, j SHAW, PITTMAN, POTTS & TROWBRIDGE

~

T lta.cT\ *l c r. .

J. Patrick Hickey, P.C.

4 David R. Lewis

, Counsel for GPUN i

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,- UNITED STATES OF AMERICA '87 FEB 24 P2 :04 NUCLEAR REGULATORY COMMISSION BeforetheAdministrativeLawJudceI[0C2f.,A  : e NY MMa o In the Matter of )

)

GPU Nuclear Corporation ) Docket No. 50-320

) License No. DPR-73

) EA-84-137 (Three Mile Island Nuclear )

Station, Unit No. 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "GPU Nuclear ;

~

Corporation's Response to NRC Staff's Second Set of Interrogato- ,

ries" were served by deposit in the United States Mail First ,

Class, postage prepaid this 19th day of February, 1987, to the . . -

following persons:

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 <C' 33 David R. Lewis Dated

February 19, 1987 l

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