ML20011A281

Second Set of Discovery Requests Re Review & Analysis of Tests & Exams Administered by Licensee or Consultant to TMI-1 Operators & Candidates

ML20011A281
Person / Time
Site:	Three Mile Island
Issue date:	10/02/1981
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Aamodt AAMODTS
References
ISSUANCES-SP, NUDOCS 8110080438
Download: ML20011A281 (3)

Text

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LIC 10/2/81 i

J f' UNITED STATES OF AMERICA /

l NUCLEAR REGULATORY COMMISSION to o

- OSM y Cy Before the Atomic Safety and Licensing Board

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In the Matter of )

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METh0POLITAN EDISON COMPANY ) Docket No. 50-289 SP (Three Mile Island Nuclear )

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.2_ OCT 71981m '-s LICENSEE'S SECOND SET OF DISCOVERY REQUESTS ADDRESSED k'\" /

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1. With respect to the Aamodts' review and ana.'.ysis of i

tests and examinations administered by Licensee or its consultants I to TMI-1, operators and candidates for operating licensas, identify each answer or set of answers which the Aamodts claim, individually 1

or collectively, constitute evidence of cheating or possible cheating. With respect to each such answer or set of answers:

i (a) Give the designation and date of the test l or examination involved; .

(b) Using letter designations supplied by Licensee, identify the operators and candidates claimed to be involved in cheating or possible cheating; 4

and (c) Explain fully the basis on which the Aamodts l claim that there is evidence of chea ng or

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PDR ADOCK 05000289 PDR possible cheating. fg\ l O

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2. Provide the name, address, occupation and qualifications of each person who assisted the Aamodts in~ reviewing the tests and examinations identified in item 1 above.

DATED: October 2, 1981.

SHAW, PITTMAN, POTTS & TROWBRIDGE l

1800 M Street, N.W.

l: Washington, D.C. 20036 i (202) 822-1000 i

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-md.1 T. Tr6kbr'idge f rne t L. Blake, Jr.

l Counsel for Licensee ,

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UNITED STATES OF AMERICA . ,3 NUCLEAR REGULATORY COMMISSION [2 gpp y @

BEFORE THE ATOMIC SAFETY AND LICENSING BOAR gh In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

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(Three Mile Island Nuclear. )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Discovery Requests Addressed to the Aamodts in Reopened Hearing" and " Licensee's Second Set of Discovery Requests Addressed to the Aamodts," both dated October 2, 1981, were hand delivered on Octo-ber 2, 1981 to the Aamodts, TMIA and the NRC Staff; and have been served on the following persons by deposit in the United States mail, postage prepaid, this 5th day of October, 1981: j Administrative Judge Ivan W. Smith (2) Robert Adler, Esquire Chairman, Atomic Safety and Licensing Karin W. Carter, Esquire Board Assistant Attorney General U.S. Nuclear Regulatory Commission 505 Executive House , l Washington, D.C. 20555 Post Office Box 2357 Harrisburg, Pennsylvania 17120 )

Administrative Judge Gary L. Milhollin Docketing and Service See, tion (3)i  !

Atomic Safety and Licensing Board Office of the Secretary 1815 Jefferson Street U.S. Nuclear Regulatory CommissioSD Madison, Wisconsin 53711 Washington, D.C. 20555 I i

.&./ h f Ge[rgeF. Trowbridge [

Dated: October 5, 1981

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