ML19257B951
| ML19257B951 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/07/1980 |
| From: | Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML19257B949 | List: |
| References | |
| NUDOCS 8001210311 | |
| Download: ML19257B951 (34) | |
Text
i 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1)
LICENSEE'S RESPONSE TO INTERROGATORIES (SECOND SET) 0F THREE MILE ISLAND ALERT, INC.
INTERROCATORY NO. 1 Does Licensee presently measure releases of Strontium 89 and 90?
INTERROGATORY NO. 2 If so, state:
(a) What type of equipment is used; (b) Where is it located; (c) Who maintains the equipment; (d) State the mathematical formula for converting the releases measured to man-rems.
RESPONSE
- 1. Yes. In accordance with Technical Specification requirements, Licensee measures for releases of Strontium 89 and 90 in both liquid and airborne effluents.
2.
THE FOLLOWING DATA APPLIES TO LIQUID RADIOSTRONTIUM EFFLUENTS -
(a)
Continuous composite samples are taken for all radioliquid -
discharges from TMI. These daily composite samples are recomposited into one monthly sample which is analyzed for Sr-89 and Sr-90. An ISCO Model 1580 continuous composite eco1a,o .4
t sampler is used.
(b) The sampler is located in the RAD discharge pit which is the final sampling point just immediately prior to discharge from the island. The sampling point is known as 10S1 in the Radiological Environmental Monitoring Program (REMP).
(c) The sampling equipment is maintained by the Licensee's Maintenance Department.
(d) The water samples are sent to independent analytical laboratories for water chemical separation and low level counting. The results in microcuries per cc are then con-verted to dose to the maximum individual and to the population using the meth(ds described in U.S. NRC Regulatory Guide 1.109 entitled, " Calculation of Annual Doses To Fbn From Routine Releases of Reactor Effluents For The Purpose of Evaluating Compliance With 10CFR Part 50, Appendix I, USNRC, Rev. 1, October, 1977".
THE FOLLOWING DATA APPLIES TO AIRBORNE RADIOSTRONTIUM EFFLUENTS (a) A Victorcen particulate air monitor utilizing a glass fiber filter paper is used for collection of airborne radiostrontium.
(b) The final airborne sampling points for TMI-l are located in the Unit 1 auxiliary building and are designated RMA-8 (auxiliary and fuel handling building monitor) and RMA-9 (reactor building stack monitor) . The final airborne sampling point for TMI-2 is at the top of the Unit 2 vent and is designated HP-R-219.
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(c) The equipment is maintained by Licensee's Instrument and Control Departments.
(d) The air particulate samples are sent to outside laboratories where chemical separation and low level counting are done.
The results in microcuries per cc are then converted to dose to the maximum individual and to the population using the methods described in U.S. NRC Regulatory Guide 1.109 entitled,
" Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents For The Purpose of Evaluating Compliance With 10CFR Part 50, Appendix 1, USNRC, Rev. 1, October, 1977".
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s INTERROGATORY NO. 3 What was the range of Licensee's noble gas effluent monitors at the time of the March 28, 1979 accident?
RESPONSE
10 cpm with the sensitivity of 3.55x10 cpm /uC1/cc.
% 0 11774 247
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INTERROGATORY NO. 4 How many noble gas effluent monitors were operating at the time of the March 28, 1979 accident?
RESPONSE
Licensee assumes that this interrogatory inquires as to the noble gas effluent monitors at TMI-2. Five noble gas ventilation effluent monitors, plus three Waste Gas Decay Tank effluent monitors, were operating at the time of the accident. These monitors are:
Noble Gas Ventilation Effluent Monitors HP-R-219 HP-R-221A HP-R-221B HP-R-228 VAR-748 Waste Gas Decay Tank Effluent Monitors WDG-R-1480 WDG-R-1485 WDG-R-1486 1774 248
4 INTERROGATORY NO. 5
~
Did the Licensee have iodine gaseous effluent monitor operating at the time of the March 28; 1979 accident?
INTERROGATORY NO. 6 If not:
(a) How were iodine gas releases nonitored; (b) What was the amount of iodine gas released and measured for the thirty (30) day period following the March 28, 1979 accident; (c) What other persons or governmental agencies took measurements of iodine gas.
RESPONSE
- 5. Yes.
- 6. (a) No response required.
(b) No response required.
(c) No response required.
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INTERRCCATORY NO. 7 How many in-containment radiation level monitors exist in TMI-2?
INTERROGATORY NO. 8 How many were operating at the time of the accident?
RESPONSE
- 7. Six
- 8. Six 3774 250
INTERROGATORY NO. 9 Did the March 28 accident cause the effluent monitors to go off-scale?
INTERROGATORY NO. 10 If so, did all the effluent monitors go offscale?
INTERROGATORY NO. 11 If not, (a) List the location and description of each monitor that went offscale.
(b) For those monitors that went offscale, how did Licensee quantify the radioactive releases.
RESPONSE
- 9. Yec
- 10. Four of the five ventilation effluent monitors went offscale.
- 11. The four monitors which went offscale were:
(a) HP-R-219 Station Vent: Particulate-Iodine-Gas HP-R-221A Fuel Handling Building - Upstream: Particulate-Iodine-Gas HP-R-221B Fuel Handling Building - Downstream:
Particulate-Iodine-Gas HP-R-228 Auxiliary Building - Downstream: Particulate-Iodine-Gas (bl The methods used by Licensee to quantify the radioactive releases from the TMI-2 accident are described in
" Assessment of Offsite Radiation Doses from the Three Mile Island Unit 2 Accident," TDR-TMI-ll6 (Rev. O July 31, 1979).
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INTERROGATORY NO.12
~
If portable monitors were used, stata:
(a) The manufacturers; (b) The model number; (c) Age of equipment; (d) The date prior to the accident in which it was last tested; (el How f requently the equipment had been tested in the.12 months prior to the accident.
RESPONSE
(a) The manufacturers of the Multi Channel Analyzer system were Canberra, Nuclear Data and Packards The portable survey meters were manufactured by Eberline. Instrument Corporation of Santa Fe, New Mexico s (b) The model numbers.are PIC6A, R0-2 and E-520.
(c) All monitors were less than five years old, some were less than one year. The majority were less than two years old.
(d) All instruments were battery tested immediately prior to use following the initiation of the March 28, 1979 accident.
(e) All survey instruments were calibrated quarterly (four tines per year) . During the early days of the emergency eight lithium drifted germanium (GeLi) detectors with multi channel analyzers and computers were used for radio effluent assessment. Each of these detectors had its calibrations checked on at least a daily basis, as well as having back -
grounds performed on at least a daily basis.
)774 252
INTERROGATORY NO. 13 If TMI-l is restarted, will the Licensee maintain a supply of potassium iodine to be distributed to the general public if an accident were to occur?
INTERROGATORY NO. 14 If so, (a) How much will be stored; (b) Where will it be located; (c) Who will make the decision to distribute it; (d) What is the distribution priority.
RESPONSE
- 13. Licensee objects to answering Interrogatory No. 13 on the grounds that TMIA has not identified which of its contentions the interrogatory relates to and Licensee finds no relation-ship be. tween the referenced interrogatory and any TMIA contention.1/ As a result, Licensee concludes that the information sought by TMIA is not properly discoverable.
To the extent the referenced interrogatory may in TMIA's view relate to contentions of another party, TMIA has failed to identify such contentions. Licensee's objection is also grounded on the undue burden resulting from having to respond to discovery related only to another intervenor's contentions.
Given the number of intervenors in this proceeding, the numerous contentions and complexity of those contentions, and the limited time available for discovery, requiring Licensee 1/
In its First Set of Interrogatories TMIA identified the contentions associated with the interrogatories it propounded.
For some unknown reason, TMIA chose not to follow this laudable approach in its Second Set of Interrogatories.
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- i to respond to discovery requests unconnected with the e discovering party's contentions is inconsistent with the Licensing Board's direction that the intervening parties attempt to voluntarily " designate a singic spokesman or lead spokesman on major issues" (First Special Prehearing Conference Order at 65). Allowing nonsponsoring parties to propound discovery on other intervenors' contentions duplicates paperwork, leads to an unfocused and disparate approach to major issues, and results in a totally unnecessary burden on Licensee.
- 14. Licensee objects to answering Interrogatory No. 14 for the reasons set forth in Licensee's Response to Interrogatory No. 13.
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INTERROCATORY NO. 15 During the 18 months before the accident, did the Licensee have mechanical prablems with the condensate polishers in either TMI-1 or TMI-27 INTERROGATORY NO. 16 If so, (a) List the date of each such problem; (b) State what actions Licensee took to correct the problem; (c) State whether the Licensee reported these problems to:
(i) The manufacturer, and, if so, when and to whom; (ii) The NRC, and, if so, when and to whom.
RESPONSE
- 15. Licensee had certain mechanical problems with the condensate polishers for both TMI-l and TMI-2 during the 18 month period prior to March 28, 1979.
- 16. (a) The requested information is contained in four computer printouts, namely: Corrective Maintenance Component History Report Met-Ed TMI Unit 2; Corrective Maintenance Component History Report Met-Ed TMI Unit 1; Preventive Maintenance Results Record by Component Met-Ed TMI Unit 2; ar.d Preventive Maintenance Results Record by Component Met-Ed TMI Unit 1.
(b) This information also is found in the documents identified in response to Interrogatory No. 16. (a).
(c) (1) Licensee did not report this information to the manufacturer.
(ii) Licensee did not report this information to the NRC.
'I .
177g 255
g INTERROGATORY NO. 17 Did a 1977 management audit of GPU, by Booz, Allen and Hamilton recommend integrating the management of GPU Service Corporation and Met-Ed?
INTERROGATORY NO. 18 If so, (a) Were the recommendations followed; (b) If not all were followed, which ones were; (c) What were the dates that the recommendations accepted were ,
implemented?
RESPONSE
Licensee objects to answering Interrogatory Nos. 17 and 18 for the reasons set forth in Licensee's response to Interrogatory No.
13.
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INTERROGATORY NO. 19 Does the Licensee have a quality assurance plan for TMI-l?
INTERROGATORY NO. 20 If so, (a) How many inspectors are provided for; (b) Who has the responsibility for maintaining the "as-built" drawings; (c) When was the last time, prior to the March 28 accident, that plant procedures for TMI-l were reviewed; (d) List the name, address and telephone number of each TMI-l quality assurance inspector who was:
(i) Dismissed (ii) Suspended (iii) Reprimanded (iv) Demoted (v) Reassigned for the twelve months preceding the TMI-2 accident.
(e) Supply copies of the quality assurance plan in effect on Fbrch 27,1979, and the present plan.
RESPONSE
Licensee has answered these interrogatories to the extent that they relate to TMIA Contention No. 5, dealing with Licensee's maintenance practices.
- 19. Yes.
- 20. (a) Presently, there are 23 qualified TMI Generation Division inspectors (including contractor personnel) available at TMI and qualified in various inspection disciplines to support maintenance activities for TMI-l and TMI-2.
(b) The TMI Generation Group Technical Function Department has the responsibility for maintaining "as built" drawings.
(c) The requested information is contained in the Licensee's 1979 Procedure Review Schedule.
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4 (d) (i) None (ii) None (iii) None (iv) None (v) T.A. O' Conner and W.W. Cotter were reassigned as a result of promotions. J.V. Principe was reassigned to another work location. The address of Mr. O' Conner is Metropolitan Edison Company, P.O. Box 480, Middletown, Pennsylvania 17057.
The address of Mr. Cotter and Principe is P.O. Box 458, Portland, Pennsylvania 18351.
(e) Licensee's quality assurance plan for TMI-l is Operational QA Plan Revision 7, which was in effect on March 27, 1979 and presently remains in effect.
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4 INTERROGATORY NO. 21 Does Licensee have operating and emergency procedures for TM1-l?
INTERROGATORY NO. 22 If so, supply the most recent copy and a copy of the procedure in effect one (1) month prior to March 28 accident at Unit 2.
RESPONSE
Licensee objects to answering Interrogatory Nos. 21 and 22 for the reasons set forth in Licensee's response to Interrogatory No. 13.
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INTERROGATORY NO. 23 Are equipment maintenance records kept by the Licensee?
INTERROGATORY NO. 24 If so, provide copies of the maintenance records of TMI-l for the six (6) months prior to the accident for the following equipment:
(a) Valves in TMI-l containment building; (b) Pressurizer level transmitter; (c) Hydrogen recombiner; (d) Pressurizer heaters; (e) Make-up pump switches; (f) Condensate polishers.
RESPONSE
- 23. Licensee keeps equipment maintenance records for TMI-l in the form of Generation Maintenance System Corrective Fbintenance Component History Reports - TMI Unit 1; Preventive Fbintenance Results Record by Component - TMI Unit 1; and Generation Corrective Maintenance System Job Tickets (Work Requests) -
Three Mile Island.
- 24. The records identified in the response to Interrogatory 23 include the information for the equipment itemized in Interrogatory Nos. 24 (a) through (f).
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i INTERROGATORY NO. 25 Does Licensee have a program for training of operators at TMI-l?
INTERROGATORY NO. 26 If so, (a) Who developed the program; (b) Where was it developed; (c) Has it been updated, and if so, list the date of each update.
INTERROGATORY NO. 27 Have any employees of Licensee or consultants suggested changes or criticized the plan?
INTERROGATORY NO. 28 If so, (a) Supply the name, address and telephone number of each person who voiced the criticism or suggested the changes; (b) When was the criticism communicated; (c) When were the suggested changes communicated; (d) When were the changes implemented; (e) If these criticisms or suggestions were in writing, supply copies.
INTERROGATORY NO. 29 If they were not all implemented, (a) Which ones were; (b) Provide the name, address and telephone numbers of those persons who decided which ones were to be implemented; (c) When were they completed; (d) Supply copies of any internal evaluations of the criticisms or suggestions.
RESPONSE
Licensee objects to answering Interrogatory Nos. 25, 26, 27, 28 and 29 for the reasons set forth in Licensee's response to Interrogatory No. 13.
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INTERROGATORY NO. 30 During and af ter the accident, were any f acilities associated with TMI-l used to deal with the accident.
INTERROGATORY NO. 31 If so, (a) What facilities were used; (b) For what period of time; (c) Were the facilities used contaminated, and, if so:
(i) Are they still contaminated;
~
(ii) When will they be decontaminated.
RESPONSE
- 30. Yes.
- 31. (a) through (c). See Interrogatory No. 31 (Second Set)
Attachment A.
o THREE MILE ISLAND ALERT, INC.
INTERROGATORY No. 31 (SECOND SET)
ATTACHMENT A 31.(a) 31.(b) 31.(c) 31. (c) (1) 31. (c) (ii)
Radwaste Evaporator 4/1/79*-4/15/79* yes yes prior to TMI-l restart Fuse. Waste Storage Tank 4/1/79*-12/1/79 yes yes prior to TMI-1 restart Neuttilizer Feed Tank 4/18/79 ** yes yes prior to TMI-1 restart Neutralized Waste Storage Tank 4/21/79 ** yes yes prior to TMI-1 restart Concentrated Waste Storage Tank 4/1/79 ** yes yes prior co TMI-1 restart Waste Evaporator Condensate Storage Tanks 4/1/79 ** yes yes prior to TMI-l restart Control Room 3/28/79-7/15/79* no n/a n/a Radiological Chemical Sample Room 3/28/79 ** yes yes prior to TMI-1 restart Radiological Chemical Lab 3/28/79-5/15/79* no n/a n/a b Primary Chemical Lab 3/28/79 ** yes yes prior to TMI-1 restart ?
Decontamination Facility 3/28/79 ** yes yes prior to TMI-1 restart Chemical Addition Room 4/15/79-9/1/79 no n/a n/a Turbine Building-305 Elevation 5/1/79-11/15/79 no n/a n/a Circulating Water Pump House 4/15/79-6/1/79 no n/a n/a EPICOR I Processing Facility 4/6/79 ** yes yes prior to TMI-l restart
- Approximate date
- Still in use N .
N. .
N CP u'
INTERROGATORY No. 32 Did Licensee ever enploy one Norman Reismiller on any operation relating in any way to Three Mlle Island?
INTERROCATORY NO. 33 If so, please supply:
(a) The dates of employment; (b) His duties; (c) His address and telephone number.
RESPONSE
Licensee has answered these interrogatories to the extent that they relate to TMIA Contention No. 5, dealing with Licensee's maintenance practices.
Licensee did employ Norman Reismiller (Norman C. Reismiller) in connection with maintenance at Three Mile Island.
(a) He was employed, based upon payroll records, from October 3, 1957 to May 31, 1978.
(b) He performed machinist and mechanical maintenance functions.
(c) His last known address is 7 George Drive, Middletown, Pennsylvan,ia 17057.
=4.
f774 264
i e
a
. INTERROGATORY NO. 34 With respect to the following persons, please supply the same information requested for Norman Reismiller in Interrogatory Number 33 above:
(a) Richard Blakeman; (b) Thomas Leach; (c) Dave Labby; (d) Paul Baker.
RESPONSE
As with respect to Interrogatory Nos. 32 and 33, Licensee has answered this interrogatory to the extent it relates to TMIA Contention No. 5, dealing with Licensee's maintenance practices.
(a) Richard Blakeman (Albert R. Blakeman), based upon payroll records, was employed by Licensee at Three Mile Island from December 15, 1977 to August 31, 1978 and performed super-visory function with respect to mechanical maintenance.
Mr. Blakeman's last known address is Box 1447, Gibson, B.C.,
Canada VONIVO.
(b) Because the. primary duties of Thomas Leach when he was employed by Licensee at Three Mile Island did not relate to maintenance, Licensee objects to Interrogatory No. 34(b). Nonetheless, since TMIA might view some of Mr. Leach's work assignment as relating to maintenance, Licensee provides the following information:
Thomas Leach, based upon payroll records, was employed by Licensee at Ttiree Mile Island from January 7, 1974 to March 29, 1979 and performed health physics and chemistry functions.
Mr. Leach's last known address is 713 Garden Drive, liarrisburg, Pennsylvania 17111.
1774 265'
(c) Dave Labby (David G. Labby), based upon payroll records, was employed by Licensee at Three Mile Island from October 23, 1973 to April 30, 1977 and performed mechanical maintenance functions.
Mr. Labby's last known address is P.O. Box 54, Bainbridge, Pennsylvania 17502.
(d) Paul Baker (Par.1 M. Baker), based upon payroll records, was employed by Licensee at Three Mile Island f rom October 24, 1973 to July 31, 1977 and performed mechanical maintenance functions.
Mr. Baker's last known address is R.D. #3, Box 365, Elizabethtown, Pennsylvania 17022.
0 0 9 (774266
i, ,
INTERROCATORY NO. 35 Please supply the names of all employees associated with TML in any way who left their employment at the island within three (3) weeks of the accident.
RESPONSE
Licensee objects to answering Interrogatory No. 35 for the reasons set forth in Licensee's response to Interrogatory No. 13.
6 i774267
s INTERROGATORY No. 36 Please supply all time records indicating the hours worked for each employee having any responsibilities related to any maintenance or repair operation conducted during any outage or
" scram" for TMI-1 or TMI-2 during the eighteen (18) months prior to the accident.
RESPONSE
Licensee objects to answering Interrogatory No. 36 due to the tremendous burden associated in producing the requested documents.
In order to respond, Licensee first would have to determine which employees performed maintenance or repair work during all TMI outages during the 18 months prior to the accident. Once that list was generated, Licensee then would have to search manually its time records to locate the desired documents. It is estimated that for the relevant time period there are 200,000 time sheets and 100,000 time books that would have to be reviewed. These time records are located at TMI and Licensee's offices in Lebanon and at Reading, Pennsylvania. Licensee has made a rough, ballpark estimate of the time necessary to produce the relevant documents, and believes that it most likely is in excess of two man-years.
If TMIA is interested in pursuing the matter, and desires to conduct the search itself, Licensee would be willing to discuss with TMIA procedures whereby a representative of TMIA could be given access to the Licensee's time records.
1774 268
s* .
INTERROGATORY NO. 37 Supply the names, addresses and telephone numbers of all health physicists employed at TMI since the beginning of operations, showing their dates of employment and describing their duties.
RESPONSE
Licensee objects to answering Interrogatory No. 37 for the reasons set forth in Licensee's response to Interrogatory No. 13.
Respe.tfully submitted, SilAW, PIT o i POTTS & TROWBRIDGE By: ,-( l\b C4yn Robett E. Zahl Dated: January 7, 1980 1774 269
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
METROPOLITAN EDISON COMPANY e ar (Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF WILLIAM E. RIETHLE WILLIAM E. RIETHLE, being duly sworn according to law, deposes and says that he is Supervisor, TMI Environmental Impact Assessment Group with GPU Service Corporation; that the information contained in Licensee's Response to Interrogatory Nos. I through 12, both inclusive, is true and correct to the best of his knowledge, information and belief.
h Wil'liam E. Riethle Supervisor, TMI Environmental Impact Assessment Group Sworn to and subscribed before me thisif k day of January, 1980.
e mb d Notary' pub {/c
)
k My Commission expires V
d% $ $_/7 Q
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.1774 27 d
i UNITED STATES OF AMERICA NUCLEAR RFCULATORY C0FDf1SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
METROPOLITAN EDISON COMPANY e r (Three Mile Island Nuclear ) .
Station, Unit No. 1) )
AFFIDAVIT OF DANIEL M. SHOVLIN DANIEL M. SHOVLIN, being duly sworn according to law, deposes and says that he is Superintendent of Maintenance-Nuclear with Metropolitan Edison Company; that the information contained in Licensee's Response to Interrogatory Nos. 15, 16, 23 and 24 is true and correct to the best of his knowledge, information and belief.
O d h >Jxn d ~'
Daniel M. Shovlin Superintendent of Maintenance-Nuclear Sworn to and subscribed before me this L) M day of January, 1980.
Mo s; - 11, a Notary @ublic (, 1 My Commission expires N 9 3,l7 N U
1774 27P
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the 16tter of )
METROPOLITAN EDISON COMPANY (Re ar (Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF NICHOLAS C. KAZANAS State of New Jersey )
- SS County of )
NICHOLAS C. KAZANAS, being duly sworn according to law, deposes and says that he is Manager of Quality Assurance with GPU Service Corporation; that the information contained in Licensee's Responses to Interrogatory Nos. 19, 20(a), 20(b), 20(c) and 20(e) are true and correct to the best of his knowledge, information and belief.
Nicholas C. Kazanas Manager of Quality Assurance Sworn to and subscribed before me this day of January, 1980.
Notary Public My Commission Expires g # .
17174 272
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
~
METROPOLITAN EDISON COMPANY ) e
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF THOMAS L. HOMBACH THOMAS L. HOMBACH, being duly sworn according to law, deposes and says that he is Director-Division Personnel-Administration with Metropolitan Edison Company; that the information contained in Licensee's Response to Interrogatory Nos. 20(d), 32, 33 and 34 is true and correct to the best of his knowledge and belief.
h _ "t Thomas L. Hombach Director-Division Personnel-Administration Sworn to and subscribed before me this Ll day of January, 1980.
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My Commission expires W 9k((hI '
U 1774 273
,s.
UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
METROPOLITAN EDISON COMPANY e ar
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF MICllAEL J. ROSS MICilAEL J. ROSS, being duly sworn according to law, deposes and says that he is TMI Supervisor of Operations - Unit I with Metropolitan Edison Company; that the information contained in Licensee's Responses to Interrogatory Nos. 30 and 31 are true and correct to the best of his knowledge, information and belief.
2nDX Michael J. Ross V
~
7 TMI Supervisor of Operations - Unit 1 Sworn to and subscribed before me thisli k day of January, 1980.
91 -
NotarffPubfic My Commission expires V
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1774 274
,.o UNITED STATES OF AFERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1)
CERTIFICATE OF SERVICE I hereby certify that copies of Licensee's Response to Interrogatories (Second Set) of Three Mile Island Alert, Inc. dated January 7, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage paid, this 7th day of January, 1980.
A") &
- RoEert Zahler Dated: January 7, 1980.
1774 27S
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1)
SERVICE LIST Ivan W. Smith, Esquire Karin W. Carter, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 Nor. , Front Street Oak Ridge, Tennessee 37830 Harrisbw g, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township Washington, D.C. 20555 T.M.l. Steering Committee 2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Commission Widoff Reager Selkowitz & Adler P.O. Box 3265 P.O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105
- Person on whose behalf service is being made. Only Certificate of Service is enclosed. ,
lir7 4 276 -
,.s Ellyn Weiss, Esquire Robert Q. Pollard Sheldon, Harmon & Weiss Chesapeake Energy Alliance Suite 506 609 Montpelier Street 1725 Eye Street, N.W. Baltimore, Maryland 21218 Washington, D.C. 20006 Chauncey Kepford Steven C. Sholly Judith H. Johnsrud 304 South Market Street Environmental Coalition on Nuclear Power Mechanicsburg, Pennsylvania 17055 433 Orlando Avenue State College, Pennsylvania 16801 Holly S. Keck Legislation Chairman Fbrvin I. Lewis Anti-Nuclear Group Representing 6504 Bradford Terrace York Philadelphia, Pennsylvania 19149 245 Wesi Philadelphia Street York, Pennsylvania 17404 Marjorie M. Aamodt R.D. 5 Karen Sheldon, Esquire Coatesville, Pennsylvania 19320 Sheldon, Harmon & Weiss Suite 506 George F. Trowbridge, Esquire
- 1725 Eye Street, N.W. Shaw, Pittman, Potts 6 Trowbridge Washington, D.C. 20006 1800 M Street, N.W.
Washington, D.C. 20036
- Person on whose behalf service is being made. Only Certificate of Service is enclosed.
]774 277'