ML20137P126

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Petition of GP Miller for Leave to Intervene in Proceeding. Miller Can Present Testimony to Contribute to Development of Adequate Record on Issues.Notice of Appearance & Certificate of Svc Encl.Served on 860203
ML20137P126
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/29/1986
From: Maupin M
HUNTON & WILLIAMS
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20137P132 List:
References
CON-#186-951 LRP, NUDOCS 8602040342
Download: ML20137P126 (8)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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INQUIRY INTO THREE MILE ) Docket No. LRP ISLAND UNIT 2 LEAK RATE )

DATA FALSIFICATION )

PETITION TO INTERVENE OF GARY P. MILLER Gary P. Miller hereby petitions to intervene in this proceeding.

1. During the period February 2, 1978 through March 28, 1979, Mr. Miller served at various times as Unit Superintendent of Three Mile Island Unit II, Station Superintendent of the Three Mile Island Nuclear Station (the Station), and Station Manager of the Station.
2. Mr. Miller's future professional status may ultimately be affected by this proceeding.
3. Pursuant to the Commission's Order and Notice of Hearing, dated December 18, 1985, the Presiding Board is to address, among others, these issues:

(a) How were the Technical Specification 3.4.6.2 requirements for reactor coolant system 8602040342 860129 PDR ADOCK 05000320 0 PDR

unidentified leakage interpreted and

..splemented by . . . on-site . . . management?

Following the discovery by an NRC inspector in October 1978 that Technical Specification 3.4.6.2 requirements were not properly interpreted or implemented, what corrective action was taken by management personnel?

Mr. Miller can present testimony that will contribute to the development of an adequate record on these issues.

In short, Mr. Miller has an interest that may be affected by this proceeding, and it is likely that he will contribute to development of an adequate record. He should be made a party to this proceeding.

Respectfully submitted, GARY P. MILLER By Michael W. Maupin, Counsel Of Counsel Michael W. Maupin l

Maria C. Hensley HUNTON & WILLIAMS P.O. Box 1535 Richmond, Virginia 23212 Dated: January 29, 1986 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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INQUIRY INTO THREE MILE ) Docket No. LRP ISLAND UNIT 2 LEAK RATE )

DATA FALSIFICATION )

CERTIFICATE OF SERVICE I certify that copies of Petition to Intervene of-Gary P. Miller, dated January 29, 1986, were served upon the following persons by deposit in the U.S. Mail, first class, postage prepaid, today:

Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Chief, Docketing and Service Section Presiding Board l

TMI Leak Rate Data Proceeding U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8

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Jack R. Goldberg, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Harry H. Voigt, Esquire LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 Smith B. Gephart, Esquire Killian & Gephart 218 Pine Street Harrisburg, Pennsylvania 17108 James B. Burns, Esquire Isham, Lincoln & Beale 3 First National Plaza Chicago, Illinois 60602 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 h A 'J M Michael W. Maupin Counsel for Gary P. Miller Dated: January 29, 1986

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INQUIRY INTO THREE MILE ) Docket No. LRP ISLAND UNIT 2 LEAK RATE )

DATA FALSIFICATION )

NOTICE OF APPEARANCE The undersigned, an attorney-at-law in good standing admitted to practice before the Supreme Court of Virginia, enters his appearance in this proceeding as counsel on behalf of Gary P. Miller, RD 2, Box 425, Fairview Road, Columbia, Pennsylvania 17512.

Respectfully submitted, l

Michael W. Maupin HUNTON & WILLIAMS P.O. Box 1535 Richmond, Virginia 23212 (804) 788-8372 i

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INQUIRY INTO THREE MILE ) Docket No. LRP ISLAND UNIT 2 LEAK RATE )

DATA FALSIFICATION )

i NOTICE OF APPEARANCE The undersigned, an attorney-at-law in good standing admitted to practice before the Supreme Court of Virginia, enters her appearance in this proceeding as counsel on behalf of Gary P. Miller, RD 2, Box 425, Fairview Road, Columbia, Pennsylvania 17512.

Respectfully submitted, I

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1/ January 29, 1986 M\ N UNITED STAT OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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INQUIRY INTO THREE MILE ) Docket No. LRP ISLAND UNIT 2 LEAK RATE )

DATA FALSIFICATION )

CERTIFICATE OF SERVICE I certify that copies of Notices of Appearance of Michael W. Maupin and Maria C. Hensley, dated January 29, 1986, were served upon the following persons by deposit in the U.S. Mail, first class, postage prepaid, today:

Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Chief, Docketing and Service Section Presiding Board TMI Leak Rate Data Proceeding U.S. Nuclear Regulatory Commission Washington, D.C. 20555 F

I Jack R. Goldberg, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Harry H. Voigt, Esquire LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 Smith B. Gephart, Esquire Killian & Gephart 218 Pine Street Harrisburg, Pennsylvania 17108 James B. Burns, Esquire Isham, Lincoln & Beale 3 First National Plaza Chicago, Illinois 60602 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ab d" Michael W. Maupin Counsel for Gary P. Miller Dated: January 29, 1986 i

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