|
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20148P2031988-04-0404 April 1988 NRC Staff Response to Supplemental Interrogatories from TMI Alert/Susquehanna Valley Alliance.* Related Correspondence ML20150F8851988-03-30030 March 1988 Answers to Sva/Tmi Alert Second Set of Interrogatories to Util.* Submits Responses to Sva/Tmi Alert 880315 Interrogatories.W/Certificate of Svc.Related Correspondence ML20150D0561988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20150D0441988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to Gpu Nuclear.* Related Correspondence ML20149N0461988-02-22022 February 1988 NRC Staff Response to Interrogatories from TMI Alert/Sva.* Responds to Interrogatories Filed by TMI Alert/Sva on 880207.NRC Waived Requirement for Order from Presiding Officer Directing Discovery.Related Correspondence ML20196F1181988-02-22022 February 1988 Responses to NRC Interrogatories.* All Responses Re Disposal of Accident Generated Water by Intervenor F Skolnick. Certificate of Svc Encl.Related Correspondence ML20149M8671988-02-22022 February 1988 Licensee Response to Sva/Tmi Alert Request for Production of Documents.* Documents Re Disposal of accident-generated Water Will Be Made Available for Insp & Copying as Listed. Certificate of Svc Encl.Related Correspondence ML20149M8621988-02-19019 February 1988 Licensee Answers to Sva/Tmi Alert Interrogatories to Gpu Nuclear Corp.* Responds to Sva/Tmi Alert Interrogatories Re Disposal of accident-generated Water.Related Correspondence ML20149K8801988-02-15015 February 1988 Valley Alliance/Tmi Alert Responses to Licensee Interrogatories & Request for Documents.* Info Will Be Provided Upon Availability & Listed Documents Being Sent to Licensee.W/Certificate of Svc ML20196D3731988-02-0303 February 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Util.* Original Documents Identified in Answers to Listed Interrogatories Requested.W/Certificate of Svc.Related Correspondence ML20196D3921988-01-31031 January 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Nrc.* NRC Must Produce Any Addl Documents Responsive to Request.Certificate of Svc Encl.Related Correspondence ML20148U5331988-01-29029 January 1988 Licensee Interrogatories & Request for Production of Documents to TMI Alert & Susquehanna Valley Alliance.* Joint Intervenors Should Produce Original Documents Noted in Interrogatories.W/Certificate of Svc.Related Correspondence ML20235B6151987-09-18018 September 1987 NRC Staff Sixth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories.* Staff Intends to Call C Barus as Rebuttal Witness.W/Certificate of Svc.Related Correspondence ML20214S0551987-06-0202 June 1987 Gpu Nuclear Response to NRC Staff Request for Production of Documents.* Request 1 Overly Broad,Burdensome & of Limited Relevance.Request 2 Vague.Related Correspondence ML20207S5861987-03-18018 March 1987 NRC Staff Response to Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20212N4831987-03-0505 March 1987 Gpu Nuclear Corp Response to NRC Staff Second Request for Documents.* Notes of Interviews Conducted by Stier or Associates & Certificate of Svc Encl.Related Correspondence ML20212K3891987-03-0303 March 1987 NRC Response to Gpu Nuclear Corp Third Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20212F9481987-03-0202 March 1987 Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* NRC Should Produce All Documents Required to Be Identified by Listed Interrogatories.W/Certificate of Svc.Related Correspondence ML20211F5331987-02-19019 February 1987 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 ML20211D6811987-02-19019 February 1987 NRC Fifth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Affidavit of MT Masnik Encl.Related Correspondence ML20212R6771987-01-29029 January 1987 NRC Staff Second Set of Interrogatories & Request for Documents to Gpu Nuclear Corporation.* Requests Info on 830323 Meeting W/Bechtel & Transfer or Removal of R Parks. W/Certificate of Svc.Related Correspondence ML20212R6501987-01-27027 January 1987 Gpu Nuclear Corp Third Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20207P7141987-01-13013 January 1987 Gpu Second Request for Production of Documents.* Gpu Requests That NRC Identify Title,General Subj Matter,Date, Author & Reason Why Documents Requested Being Withheld. Related Correspondence ML20207N6721987-01-0909 January 1987 NRC Staff Fourth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N7081987-01-0909 January 1987 Second Supplemental Response of Gpu Nuclear Corp to NRC Staff First Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N6911987-01-0909 January 1987 Third Supplemental Response of Gpu Nuclear Corp to NRC Staff First Set of Interrogatories.* Related Correspondence ML20207L9041987-01-0505 January 1987 NRC Staff Third Supplemental Response to Gpu First Set of Interrogatories & Request for Production of Documents.* MT Masnik & Me Resner 870105 Affidavits & Certificate of Svc Encl.Related Correspondence ML20207C4711986-12-22022 December 1986 Second Supplemental Response to NRC First Set of Interrogatories Re Util Organization & Witnesses.Certificate of Svc Encl.Related Correspondence ML20212D6651986-12-15015 December 1986 NRC Staff Second Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Unexecuted Affidavit of RA Meeks & Certificate of Svc Encl.Related Correspondence ML20211K2771986-11-13013 November 1986 Response to First Request for Production of Documents Re Basis for R Parks Removal from Test Working Group on 830223 & Parks Involvement W/Quiltech Co.Certificate of Svc Encl. Related Correspondence ML20215M9901986-10-29029 October 1986 First Supplemental Response to NRC First Set of Interrogatories Re Suspension of R Parks Employment at Facility Site.W/Certificate of Svc.Related Correspondence ML20211G5101986-10-28028 October 1986 Response to Interrogatories Re Bechtel Oct 1984 Rept, Rept of Bechtel North American Power Corp Re Allegations of Rd Parks & Eh Stier 831116 Rept, TMI-2 Rept-Mgt & Safety Allegations. Related Correspondence ML20215D8681986-10-0909 October 1986 First Request for Production of Seven Categories of Documents Re Basis for R Parks Removal from Testing Working Group on 830223 & Investigation of Parks Involvement W/ Quiltech Co.Related Correspondence ML20215D8781986-10-0909 October 1986 First Set of Interrogatories for Documents Re Identification of Util Employees Providing or Receiving Info Leading to Interrogation of Rd Parks Re Quiltech Co.Related Correspondence ML20215D8821986-10-0909 October 1986 Supplemental Response to Gpu First Set of Interrogatories & First Request for Documents Re Enforcement Action EA-84-137. Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20214R6291986-09-23023 September 1986 Response to Util First Set of Interrogatories & Partial Response to First Request for Production of Documents. Affidavits Encl.Related Correspondence ML20209G1681986-09-0404 September 1986 First Request for Production of Documents Identified in NRC Responses to Listed Interrogatories,Including Interrogatory 1(e) Re Protected Activity Engaged in by Parks Resulting in Alleged Discrimination Against Parks.W/Certificate of Svc ML20209G3181986-09-0404 September 1986 First Set of Interrogatories Re Removal of Rd Parks from Employment.W/Certificate of Svc ML20211E6311986-06-11011 June 1986 First Supplemental Answer to NRC First Interrogatories & Request for Production of Documents to C Husted.Rl Long Notes Produced Indicating Husted Met W/J Herbein on 811005. Related Correspondence ML20211E6601986-06-11011 June 1986 First Supplemental Answers to TMI Alert First Request for Production of Documents & First Interrogatories to C Husted. Rl Long Notes of 820527 Conversation W/Newton Encl.W/ Certificate of Svc. Related Correspondence ML20197C1931986-05-0808 May 1986 Answers to TMI Alert,Inc 860501 Supplemental Interrogatories.Certificate of Svc Encl.Related Correspondence ML20203L6011986-04-28028 April 1986 Responses to TMI Alert First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20141J3171986-04-23023 April 1986 Response to Util First Interrogatories & Request for Production of Documents Re Senior Reactor Operator Licensing Exams.Certificate of Svc Encl.Related Correspondence ML20141J4071986-04-23023 April 1986 Response to Husted First Interrogatories & Request for Production of Documents Re Alleged Cheating During Apr 1981 OL Exams.Certificate of Svc Encl.Related Correspondence ML20155F5471986-04-18018 April 1986 Supplemental Response to NRC Interrogatories 3 & 4 & Request for Production of Documents to Util.Certificate of Svc Encl. Related Correspondence ML20203B4121986-04-15015 April 1986 Response to First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20203B6311986-04-14014 April 1986 Answers to Staff First Interrogatories & Request for Production of Documents.Related Correspondence ML20202G5381986-04-0909 April 1986 First Interrogatories & Request for Production of Documents to TMI Alert Re Apr 1981 Senior Reactor Operator Exam. Certificate of Svc Encl.Related Correspondence ML20202G7361986-04-0909 April 1986 Response to TMI Alert,Inc First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20202G6651986-04-0808 April 1986 C Husted Answers to NRC First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1988-04-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] |
Text
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jo53
^'
m December 15, 1986
@IED CORRESPON04ngg 00CKETED
~
USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 86 DEC 19 P2 :38
- BEFORE TIIE ADMINISTRATIVE LAW JUDGBTfcE e - o
,. ...cr Tc ;, .,
c , ,t In the Matter of )~
) Docket No. 50-320 GPU NUCLEAR CORPORATION ) (Civil Penalty)
) License No. DPR-73
.(Three Mile Island Nuclear Station, ) - EA 84-137 Unit No. 2) -)
i NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO GPU NUCLEAR CORPORATION'S FIRST SET OF INTERRROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS I. INTRODUCTION On September 23, 1986, the NRC Staff served "NRC Staff Response to GPU Nuclear Corporation's First Set of Interrogatories" and "NRC Staff Partial Response to GPUN's First Request for Production of Documents."
In that response, the Staff noted that it intended to provide certain sup-plementary information promptly upon its becoming available, and to iden-tify or provide additional responsive documenM as appropriate. On October 9, 1986, . the Staff served "NRC Staff Supplemental Response to GPU Nuclear . Corporation's First Set of Interrogatories and NRC Staff Supplemental Response to CD"N's First Request for Production of Docu-ments. In response to discussions between the parties, additionel docu-ments were identified and/or provided under cover of letters dated October 28, 29, November 6 and 3,1986.
The Staff has again received further information from certain Com-mission offices, reviewed additional documents received therefrom, and hereby provides this supplemental response. Should further responsive 87010 PDR g y $ o hPDR 20 '
36 G
_, , ;-.~
-, 6 3
4 information for documents come to the Staff's attention, additional supple-mentation will be made.
II. ~ NRC STAFF SUPPLEMENTAL RESPONSES ,
TO INTERROGATORIES
' INTERROGATORY NO.' 20
.(a)-(c) 1. Barton's and Arnold's reactions to Parks' public statements as recorded by Gischel notes of a March 23, 1983 meeting with the -TMI-2 Staff concerning~ Parics. (Meeks)
- 2. . Kanga's reactions to' Parks' reference to the " mystery man" in
. his public affidavit as recorded by Gischel notes of Ron Warren's report on a May 4,1983 Kanga/Barton staff meeting. (Meeks)
INTERROGATORY NO. 52 Documents (639 pages) received by R. Meeks, OI, from T. Devine, GAP.- July 25, 1983 note by Mecks acknowledging raceipt of the docu-ments was identified in letter of Staff counsel, dated October 28, 1986.
- (Meeks)- .
INTERROGATORY NO. 56 The following documents have been identified as responsive to 56(e):
-1. Parks draft statement for mystery man affidavit. (Meeks) ,
- 2. See response to Interrogatory No. 52 above. (Meeks)
- 3. Note dated September 12, 1983, to Ben Hayes from Victor Stello entitled " Meeting With Larry King And Joe Chwastyk." (Meeks)
- The following documents have been identified as response to 56(f):
- 1. Memo to file, dated May 24, 1983, by William Ward entitled
" Analysis of Affidavit by Richard D. Parks." This document , which
g . . . .-
- , ,1 '
~
y : reflects a. preliminary review of. the Parks affidavit of March 21,1983, is a deliberative, recommendatory document prepared in -the course of OI's
" ~ investigation of Parks' . allegations. . It is withheld pursuant to 10 C.F.R.
6 2.790(a)(5). (Meeks)
- 2. Draft memorandum (pending March 30, 1983) from James Vorse to -- Ben llayes entitled "Three Mile Island--Investigation of Allegations
- Based ' on GAP Affidavit." This document, which describes a plan for
_ conducting an investigation of the subject matter, is a deliberative, re-commendatory -~ document prepared in the course of Ol's investigation of
- Parks' allegations and contains information which would disclose OI's in-vestigative techniques. It ' is withheld pursuant to 10 C.F.R.
. I 2.790(a)(5) and (a)(7)(v). (Meeks)
- 3. Memorandum, dated March 31, 1983, to Palladino from Ben Hayes entitled "OI Wcrk Plan Regarding Issues Raised by the Richard Parks - Affidavit." This document is a deliberative /recommendetory docu-ment prepared in the course of OI's investigation of Parks' affidavit and contains information which would disclose OI's investigative techniques.
It is withheld pursuant to 10 C.F.R. I 2.790(a)(5) and (a)(7)(v).
(Meeks) d
. INTERROGATORY NO. 59
, 1. Letter dated April 18, 1983, from Michael J. Corcoran, DOL, to James Vorse, 01, enclosing complaint of Richard Parks, etc. (Meeks)
- 2. Letter dated April 26, 1983, from Michael J. Corcoran, DOL, to James Vorse, OI, enclosing supplemental complaint of Richard Parks.
(Meeks) l l
l
+
^ -
_4
' 3. - [ POL' Notice .' of ^ Receipt of Request for Hearing concerning
' INTERROGATORY NO. 63
[The = following documents have been identified as responsive to 63(c):
1.- Handwritten inspector interview questions for Parks (undated).
This . document contains info: mation which would disclose investigative techniques . and is withheld pursuant to 10 C.F.R. $ 2.790(a)(7)(v).
(Meeks)
- 2. Handwritten draft entitled " Review of Affidavit submitted byle
- Richard . D. Parks (Long Version)" (undated). This document is a i deliberative / recommendatory document prepared in course of MRC's inves-tigation . It is withheld pursuant to 10 C.F.R. I 2.790(a)(5). (Meeks)
- 3. Two ' sets of inspector notes (one typed, one handwritten) de-
^? scribing' information obtained relating to safety allegations / polar crane
-issues- as well as planned further activities (undated). These documents are deliberative / recommendatory and are withheld pursuant to 10 C.F.R.
I 2.790(a)(5). (Meeks)
- 4. Memorandum dated May 25, 1983, from James Vorse to Ben Hayes entitled " Draft Report Regarding Inspector Findings," (the enclo-sure: two drafts of the report entitled "Results of the Investigation / Inspection and Procedural and Manageris) Deficiencies at TMI-2") . This document is deliberative / recommendatory end was prepared in the course of the investigation of the Polar Crane Program violations i
and onsite TMI-2 managerial organization. It is withheld pursuant to 10 C.F.R. I 2.790(a)(5). (Meeks)
g ~
3
~
- g. . ~
5.- Prior drafts (5) of portions of the report identified in 4 above with .the following titles:
Investigation of AIIeged Procedure Violations LAssociated with the' Reactor Building Polar Crane _ Refurbishment Program; A. Introduction (2 drafts); D. Violation of Maintenance Procedures Used During the Reactor Building Polar Crane Refurbishment (2 drafts); Re-view ' of -the Results of the Technical Examination of Alleged Procedural and- Manageric! Deficiencies at Three Mile Island Unit 2, dated August 16 1983. These documents are deliberative / recommendatory, were prepared in the course of the NRC's investigation -and are withheld pursuant to
-10 C.F.R. I 2.790(a)(5). (Meeks)
- 6. Memorandum dated October 26, 1984, from Harold Denton to Richard DeYoung entitled "OI Investigation of Polar Crane Allegations,"
enclosing October 18, 1984 memorandum from Ben Hayes to William Dircks entitled " Investigation of TMI-2 Polar Crane Allegations." These docu-ments transmit and describe OI's findings with respect to willfulness and related matters based on OI's investigation of the pelar crano allegations, for consideration by OIE. As a result , they are deliberative /
recommendatory and are withheld pursuant to 10 C.F.R. I 2.790(n)(5). .
(Meeks)
- 7. March 2, 1984 Memorandum from Ben Hayes to William Dircks entitled " Staff Actions Regarding OI--Report on TMI Cleanup Allegations" and enclosing February 24, 10F4 memorandum for Ben Hayes from R.Ds Walker and A.B. Beach entitled " Assessment of the Staff Review and Re-sponse to OI Report On TMI-2 Cleanup Allegation." Portions of these documents are deliberative /recomrendatory and are withheld pursuant to 10 C.F.R. 2.790(a)(5). (Meeks)
- -~' - -
,. . .~:-- . : .?
l INTERROGETORY NO. 65 The follow'ng documents have been identified as responsive to Interrogatory 65(i f:
Memorandum, dated July' 11, 1983, from Fred Clemenson to Rog-
~ 1.
er 1 Fortuna, entitled " Addendum No. 1 To Memorandum To Roger A.
Fortuna From Fred Clemenson, - Dated July 8,1983, Entitled ' Revisions To
' Fred Clemenson's Intitial Proposed Position On The Polar Crane Recovery Plan Quality Assursnee Requirements . And The Ressons For The Revi-sions. '" - This document is deliberative / recommendatory and is withheld
. pursuant to 10 C.F.R. I 2.790(a)(5). (Meeks)
- 2. Handwritten memorandum from J. Vorse to W. Ward entitled "TMI-2 Polar Crane Report." This document, which addresses the pro-posed report by Fred Clemenson, is deliberative / recommendatory and is withheld pursuant to 10 C.F.R. I 2.790(a)(5). (Meeks)
- 3. Memorandum from Ben IIayes, OI, to William Dircks, EDO, ' dated August 23, 1983 and entitled "TMI-2 Polar Crane Issues" (enclosing Memo from Fred Clemenson to Roger Fortuna, dated July 25, 1983 entitled "Fi-nal Draft of My Report . on Parks' Technical Allegations Regarding the TMI-2 Polar Crane" with report attached. These documents, which trans-mit and describe proposed findings concerning technical issues relating to Polar Crane allegations are deliberative / recommendatory and are withheld pursuant to 10 C.F.R. I 2.790(a)(5). (Meeks)
- 4. Memorandum from Fred Clemenson to Roger Fortuna , dated '
July 8, 1983, entitled " Revisions to Fred Clemenson's Initial Proposed Position on the Polar Crane Recovery Plan Quality Assurance Require-ments and the Reasons for the Revisions" with attachments a through f.
L i l
- . l l
.- . . . . . , . . - . - - _ _ _ . . . ~ _ . . - - , . - - _ _ . _ , _
y p This docunflent, which addresses polar crane technical /QA issues , is deliberative / recommendatory and is withheld pursuant to 10 C.F.R.
I 2.790(a)(5). (Meeks)
- 5. - Handwritten and typed drafts entitled " Summary of Three Mile
. Island Unit 2 Polar Crane Technical Concerns" (undated). These docu-ments, which appear to be drafts authored by F. Clemenson related to the documents described immediately above, are deliberative /
recommendatory and are withhsid pursuant to 10 C.F.R. I 2.790(a)(5).
(Meeks)
- 6. Handwritten markup by Fred Clemenson entitled " Technical Re-view of the Three Mile, Island Unit 2 Polar Crane Ist,ue" (undated). This document is deliberative / recommendatory and is withheld pursuant to 10 C.F.R. I 2.790(a)(5). (Meeks)
- 7. Two drafts entitled " Investigation of Three Mile Island Unit 2 Polar Crane Technical Concerns" (undated and " Final 5-26"). These doc-uments are deliberative /recommendetory and are withheld pursuant to 10 C.F.R. I 2.790(n)(5). (Meeks)
- 8. March 2,1984 memorandum from Ben B. Hayes to 171111am Dircks entitled 7'Steff Actions Regarding OI--Report on TMI Cleanup Allegations" with enclosuren. Same as document no. 7 listed under Interroga-tory 63(c). (Meeks) i INTERROGATORY 67 The following documents have been identified:
- 1. Handwritten draft entitled " Report of interview with B. Kanga on 04-29-83" (undated). This document contains inspector questions and ,
i l
,- ,--,m,---e-,,,------.-.~.,e-,. .% y,.r.m.m .,.....y.,----._,.-,,y.-% -,w -,-r.--.-w .-m_y - - < - - - - ,w-wer---
c; - - - --
. _. - . ~ . _ = , .-
3,~
z.; investigator's recordation of answers which would disclose investigative techniques and is withheld pursuant to 10 C.F.R. I 2.790(a)(7)(v).
2.- Handwritten draft entitled " Interview of Bahman K. Kanga" (fo-
' terview held. April 29. 1983). This document is a draft summary of inter-view _and contains information which would disclose investigative techniques. It is is withheld pursuant to 10 C.F.R. 5 2.790(a)(5) and 8 2.790(o)(7)(v). (Meeks)
- 7. Handwritten draft entitled " Interview of Mervyn K. Pastor" (in-terview held May 4,1983). This document is a draft summary of inter-view _and contains information which would disclose investigative techniques. It is _ withheld pursuant to 10 C.F.R. I 2.790(a)(5) and 5 2.790(a)(7)(v). (Meeks)
- 4. Handwritten draft entitled " Interview of Ronald L. Freemerman" (interview held on May 5,1983). This document is a draft summary of interview and contains information which would disclose investigative tech-niques. It is withheld pursuant to 10 C.F.R . I 2.790(a)(5) and ,
5 2.790(a)(7)(v). (Mecks)
- 5. Handwritten draft entitled " Interview of John J. Barton" (inter-
. view held May 11 and 12,1983). This document is a draft summary of interview and contains information which would disclose investigative tech-niques. It is withheld pursuant to 10 C.F.R. I 2.790(a)(5) and 5 2.790(a)(7)(v). (Meeks)
- 6. Handwritten draft entitled "Reinterview of Ronald L.
Froemerman" (interview held May 12, 1983). This document is a draft summary of interview and contains information which would disclose inves-i
- s. ,
.m . tigative techniques. It fs - withheld pursuant to 10 C.F.R. I 2.790(a)(5) and 5 2.790(a)(7)(v). (Meeks)
-INTERROGATORY NO. 6P (a)-(e) 1. Barton a:nd Arnold made statements which were wit-nessed by- the attendees at the March 23,1983 TMI-2 Staff meeting con-cerning Parks. making public statements. Gischel notes of March 23, 1983 meeting with TMI-2 Staff on Parks going public. (Meeks) 2.- Kanga made statements which were witnessed by the attendees at the f. lay 4,,1984 Kanga/Barton Staff meeting. Glechel notes of Ron Warren's report on the May 4,1983 staff meeting. (Meeks)
III. SUPPLEMENTAL NRC STAFF RESPONSE TO GPU NUCLEAR CORPORATION'S FIRST REQUEST POR PRODUCTION OF DOCUMENTS ,
As indicated in the Staff's partial response to GPU Nuclear Corpora-tion's First Request for Production of Documents, the Staff has continued its search for responsive documents. In accordance with GPUN's request for identification of documents, the Staff has identified certain additional documents in its supplemental answers to GPUN's first interrogatories.
Those documents are being provided this date under separate cover, are otherwise available to GPUN, or are being withheld from disclosure on ;
grounds identified in the Staff's supplemental answers.
j Respectfully submitted, g
Mit i . Young Counsel for NRC Staff
[ Dated at Dethesda, Maryland this 15th day of December,1986
L. .
1.
L ,e- UNITED STATES OF AMERICA y
j ,-
NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE
, ' In tho' Matter of )
) Docket No. 50-320
.y GPU NUCLEAR CORPORATION ) (Civil Penalty)
) License No. DPR-73 (Three Mile Island Nuclear Station, ) EA 84-137 Unit No. 2) )
AFFIDAVIT OF RONALD A. MEEKS I, Ronald A. Meeks, being duly sworn, state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Comminnion an a Senior Investigator, Office of Investigations, Region V. Prior to April 1984, ~!. was employed as an Investigator at OI Headquarters. A copy of
. my professional qualifications is attached.
- 2. I am duly authorized to respond to those interrogatoriec served Saptember 4, 1984 by ~ GPU Nuclear Corporallon to which my name has been appended to the answer.
I hereby certify that the. statements and opinions given are true and correct to the best of my personal knowledge and belief.
Ronald A. Meeks Subscribed and sworn to before me this day of December,1986 Notary Public My commission expires:
~- ~
- g
((
ik
}.
, - c i
s bC( d.[ (([
- UNITED STATES OF AMERICA ji NUCLEAR REGULATORY col llMISSION 1 BEFORE THE ADMINISTRATIVE LAW JUDGE E DEC 19 P2:38 CFF!D
- In the Matter of - ) $ *Ef
) Docket No. 50-320 GPU NUCLEAR CORPORATION ) (Civil Fenalty)
) License No. DPR-73 F
.(Three 14 tile Island Nuclear Station ) EA 84-137 Unit No. 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF SECOND SUPPLEPIENTAL RESPONSE TO GPU NUCLEAR CORPORATION'S FIRST SET OF INTERROGAiORIES AND RFO'19ST FOR PRODUCTION OF DOCUMENTS" in the' above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asteMak, by deposit in the Nuclear Regulatory Commission's internal mail system, this 15th day of December,1986:
- Iran W. - Smith, Esq. Ernest L. Blake, Jr.
Administrative Law Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety and Licensing Board 2300 N Street, NW U.S. Nuclear Regulatory Commission Washington, DC 20037 Washington, DC 20555
- Atomic Safety and Licensing Steven L. Hock, Esq.
Appeal Board Thelen, Marrin, Johnson, Bridges U.S. Nuclear Regulatory Commission 2 Embarcadero Center Washington, DC 20555 San Francisco, CA 94111
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 A - AW Mitzi Q. Noung / /
Counserfor NRC Staff
,