ML19262C569
| ML19262C569 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/28/1980 |
| From: | Widoff M, Widoff N THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19262C570 | List: |
| References | |
| NUDOCS 8002140525 | |
| Download: ML19262C569 (8) | |
Text
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s In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No.1)
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INTERROGATORIES OF INTERVENOR THREE MILE ISLAND ALERT, INC. TO LICENSEE (Fifth Set)
TO:
Ivan W. Smith, Esquire Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Three Mile Island Alert, Inc., by its attorneys, Widoff Reager Selkowitz & Adler, P.C. hereby files the following interrogatories pursuant to 10 C.F.R. Section 2.740(b).
These interrogatories are deemed to be continuing and shall be supplemented by Licensee when and if additional or corrective information is obtained.
1.
Has Licensee engaged the services of independent contractors to perform or supplement the performance of maintenance, repair or quality assurance functions at Three Mile Island?
2.
If so, state:
(a) the names, addresses and telephone numbers of each contractor who 800234o
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has been engaged by the Licensee since 1975; (b) the dates during which services were provided; (c) copies of executed contracts between Licensee and the contractors; (d) copies of waivers executed by any contractor or by Licensee or both relating to radiation exposure of workers, hours of employment in radioactive areas of the plant, Nuclear Regulatory Commission regulations or guidelines or liability for injury or suit or any other document that could fairly be characterized as a waiver relating to such contractors or contracts; (e) provide the names, addresses and telephone numbers of allindividuals performing maintenance, repair or quality assurance functions as officers, agents, or employees of such contractors and provide dates of employment and a description of responsibilities; e
(f) provide any evaluations or reports prepared by Licensee or in Licensee's possession which relate to work performed under such contracts; (g) with regard to such contracts or contractors, explain on what basis determinations were made to engage independent contractors as opposed to the employment of Licensee's own workers and provide copies of any reports, evaluations, or analysis of how such decisions were arrived at or that explain the rationale of Licensee in making such determinations; (h) provide copies of all reports requested or required by Licensee from contractors which document the work performed and the payments required to be paid for such work.
1) provide any documents or summaries of documents which show the hours worked at TMI by individual employees of the contractors.
3.
Provide copies of any evaluations, analyses or reports with regard to the working conditions, performance of employees or complaints of any of Licensee's employees engaged in the maintenance, repair or quality assurance function at Three Mile Island regarding working conditions or hours.
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4.
With regard to the " economy and production group" described at Page 20 of the deposition of Larry Lawyer given to the President's Commission on Three Mile Island, please provide the following information:
(a) a description of the purpose of the group, including any contemporaneous memoranda establishing the group or describing its function; (b) the names cf allindividuals constituting the c.;up; (c) the date the group was established and whether it is still functioning; (d) copies of all reports, analyses, memoranda or similar material provided by this group which contain recommendatiens or descriptions of its activities; 5.
With regard to the cut in the maintenance budget for 1979 described at Page 64 of the Deposition of Daniel Shov11n taken by the President's Commission on Three Mile Island, please provide the following:
(a) A detailed description of the budget cut and its impact both with regard to in-house maintenance and contracted maintenance;
(b) all contemporaneous memcranda, reports or analyses which relate to this budget cut including memoranda recommending the cut, dist.issing it or approving it.
6.
Please provide for inspection of the Corrective Maintenance Component History Reports - Unit 1 - for the periods January 1,1977 to September 28,1978 and for March 28,1979 to January 1,1980.
7.
Which of the following employee / hour summaries does the Licensee maintain:
A.
Weekly Recap; B.
Monthly Earnings Summary; C. Year to Date Register; D. Master File Listing?
For those which are maintained, provide a copy of each summary for the period 18 months prior to the accident.
For those not maintained, describe the system used to summarize the hours worked by individual employees and provide a copy of this summary fer the period 18 months prior to the accident.
8.
What are the account numbers assigned to the following systems in TMI Unit 1:
a) Valves in the containment building; b) Pressurizer level transmitter; c)
Hydrogen recombiner:
d) Pressurizer heaters; e)
Make-up pump switches; f)
Condensate polishers?
9.
If an account number is not assigned to a particular item listed in Interrogatory 8 above, give the account number and description of the system in which the item is included.
10.
For each account number given in response to Interrogatory 7 or 8 above, how many regular and overtime hours were accounted to maintenance and repair for the period 18 months prior to the accident?
11.
Does the Licensee m'!ntain a labor-repair summary which summarizes the weekly, monthly or yearly hours devoted to each accoun number for maintenance / repair.
If not, describe the system used for the purpose of summarizing such information.
Respe ully submitted, WID
.EAGE S VIT & ADLER,P.C.
By:
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Mr.rk P.'Wideff 6 '-
I Dated: January 28, 1980
conggp0vD NCR CERTIFICATE OF SERVICE I do hereby certify that I served a true and correct copy of the foregoing document on the below listed parties by first-class mailing:
Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 N
Dr. Walter H. Jordan g
881 West Outer Drive s
Oak Ridge, TN 37830 g
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T1 Dr. Linda W. Little p
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5000 Hermitage Drive J
Raleigh, NC 27612 c,
2 George F. Trowbridge, Esquire e,
g Shaw, Pittman, Potts & Trowbridge b
1800 M Street, N.W.
Washington, DC 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555
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Mafk P. (Vidoff '
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Dated:
January 28, 1980 8 ' g'8 e