ML20215J776

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NRC Staff Request for Production of Documents.* as Used in Request,Term Document Has Same Definition as That Set Forth in Util First Request for Production of Documents, Filed on 860923.W/Certificate of Svc
ML20215J776
Person / Time
Site: Crane Constellation icon.png
Issue date: 04/28/1987
From: Berry G
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20215J709 List:
References
CIV-PEN, EA-84-137, NUDOCS 8706250108
Download: ML20215J776 (4)


Text

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April 28,1987 II UNITED STATES OF AMERICA l

NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE I

In the Matter of

)

i

)

Docket No.

50-320 GPU NUCLEAR CORPORATION

)

(Civil Penalty).

)

License No. DPR-73 (Three Mile Island Nuclear Station

)

.EA 84-137 Unit No. 2)-

)

l MDC STAFF REQUEST FOR PRODUCTION OF DOCUMENTS The NRC Staff, pursuant to 10 C.F.R I 2.741, requests that GPU Nuclear Corporation produce for examination and copying the following:

l (1) all ' documents relating ' to all contracts, agreements, memorandum-of understanding (with '-

all amendments and protocols) ~

among GPU Corporation, Bechtel. or their subsidiaries, and the U.S. Department. of Energy (DOE) relating to TMI Unit 2 in effect at any time during the period i

May 1982 through March 1983.

This ' request includes, but is not limited to, the contracts

-e designated K9003. and - K9067 and all task orders issued ' thereunder.

This request also includes all status and performance reports made pursuant to said contracts-and task ' orders,. whether by GPUN Corporation, Bechtel or anyone acting on their behalf; and (2) all documents relating to the ~ fnterpretation an d. application of Bechtel Directive 2-1 by (a) Bechtel's Department of Internal Audits.

(b) Bechtel's Law-Department or other legal advisors, and (c) Charles W.

Sanford,

Bahman Kanga, Richard Wheeler, and any Bechtel manage-ment personnel employed at TMI-2 at any time

. during.the period May 1982 through March 1983.

8706250100g7M2 PDR ADOCK PDR Q.

[

r As u'eed in this request, the term " document" has the same definition as that se,t forth in GPU Nuclear Corporation's First Request for Production of ' Documents, f!)ed September 23, 1986.

Respectfully submitted, O

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Charles A barti

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Counsel for NRC Staff Dated at Bethesda, Mn[yland L/

this 28th day of April,1987 O

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j

BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of

)

)

Docket No.

50-320 j

GPU NUCLEAR CORPORATION

)

(Cfyil Penalty)

)

License No. DPR-73 (Three Mile Island Nuclear Station

)

EA 84-137 Unit No. 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF REQUEST FOR PRODUCTION 'OF DOCUMENTS" in the above-ccptioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 28th day of April,1987:

'Ivan W. Smith, Esq.

Ernest L. Blake, Jr.

se Administrative La Judge Shaw, Pittman, Potts & Trowbridg.

J.

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 7

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Gregory A}an B(I ry d

Counsel M NR'9 Staff

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UWt UNITED STATES OF AMERICA

,87 JUy 17 PS :44 NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE gr;;..

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Ehtht*

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)

)

1 l

1 CERTIFICATE OF SERVICE I

hereby certify that copies of "NRC STAFF MOTION TO COMPEL 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 asterisk,

by ' deposit in the Nuclear Regulatory Commission's internal mail system, this 12th day of June,1987.

  • Ivan 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 i

i 1

Charles A. Barth

~

I Counsel for NRC Staff l

1 l

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