ML19296D576
| ML19296D576 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/14/1980 |
| From: | Lewis M AFFILIATION NOT ASSIGNED |
| To: | METROPOLITAN EDISON CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8003060016 | |
| Download: ML19296D576 (6) | |
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1 3efore the Atomic s fety and Licensing oard.
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(Restart)
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%Y Further Discovery Recuests and Interrogatories by Intervence-Lewis.
Discovery Recuests for the NRC StaII.
In accordance with the directions on Page 2 of the Board's M & O dated 1 Feb 1980, Intervenor Lewis submits to the Staff the following discovery requests:'
Provide availability of the following documents in the L?DR's or send by mail to Intervenor Lewis _-
Webb R.E. "The Urgency of Closing Down Nuclear Power Plants - An Analysis of Three Mile Island Accident."
Webb R.E."The Three Mile Island Accident:Was It A Elass 9 Accident?"
Dr Webb"s Address is 2858 111 Str., Tbledo, Ohio 43611.
The following wern requested by phohe on 1-31-80, but no notice has been recieved that they were placedin the LPDR's and they have not been delivered by mail.
NUREG /CR 0315 BNL NUREG 50882 Environmental Hadiological Monitoring to Cont. Exp. Expected from Containment Release Accident. Dec 78 ACRS Subcommittee on TMI dated 6 and 7 June 1979 Pages 1 thru-405.
Nureg /CR 0774 Early Mortality Estimates for Different Nuclear Accidents dated Ap 79 and P'ublished 1979 Agust, 1.Page 2 M&O 1 Feb 1980 "The deadline for intially making dis covery requests,however, will remain for now at Febnuary 16..".
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Intervenor Lewis Third Set of Interrogatories to NRC Staff.
NRC'23.
Does the NRC keep a dossier of file on intervenors and active anti-nuclear types?
Are the names Susan Barley or Marvin I Dewis on any files in the NRC researching our backrounds, criminal records, socall contacts, hearsay, or other information which is or can be used by investigative organications within and without the government?
Intervenor Lewis is especially interseted in the type of file recently disclosed as being kept by the Georgia Power Company on. anti nuclear activists.
NRC 24. Does and other: branch of government keep a file on antinuclear activists which is available to the NRC?
Hayethe names Marvin Lewis or Susan Barley, been added to thesefilesaktherequestofordirectionfromtheNRC or any of its employees, consultants or minions?
NRC 25. Send the cirriculum vitae or Professional Qualifi cations of Dr C Gallina,who made many statements to the press during the TMI "ccident concerning releases.
i NRC 26. In the Staff s answerfs to all my previous interrogatories are all the documents to which the Staff refers in the LPDR's?
NRC27.Didtheleakingventheaderandtheh3PAandcharcoal filters meet the requirements of a.
- b. GDC 60
If any of the above are not applicable, please state why.
If these criteria were not met state specifically how and why they were not met.
( Curies, dollars pur Curie, release rate.)
- e. Include all the filters in your analysis ; not just the filters in the auxiliary building.
Why was the vert header leaking ? What materials failed?
Whare did they fail? How did they fail? When did they fa61?
If not a material problem, be specific as to what was the problem.
State who discovered leak, when, how, where. Who logged leak and when? Where is the work order to fix vent header leak?
^bove interrogatory refers to the vent header in TMI#2.NRC 27 refers to TMI#2 also.
~ Intbrvenor Lewis Third Set of Interrogatories to Licensee.
SP 25. Review all previous interrogatories to Licensee from Intervenor Lewis with the following change:
Wherever cracks are referred to in vent header change to leaks in vent header,
- a. Does this substantially change any answer to SP 1 thru 24 interrogatories?
submit
- b. If any answer is substantially changed, xamtixnew answer.
SP 26.
This is not only an interrogatory; but also a
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partial answer to the Licensee's interrogatory No 2.
Presumably the Licensee will present testimony to show that the vent header and filters are acceptable in 24I#1.
Intervenor Lewis may have to limit his presentation to cross examination of linensee's witnesses.
Send the names and qualifications of the Licensee's witnesses regarding the Lewis Contention including a syn 6psis of thsir testimony.
SP 27.
Does the Licensee keep files or dockets or dossiers on the backrounds of Marvin I. Lewis or Susna Barley?
Do these dockets contain hearsay, background checks, criminal records, or documentation from govennmental agencies?
Intervenor Lewis is particularly interested in whether Ed or its business contacts keep records of the type M-recently found to be kept by the Georgia Power Company on
- nti nuclear activists.
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UNITED STATES OF AMERICA i
NUCLEAR REGULATORY CO.'91ISSION
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O BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket No. 50-289 METROPOLITAN EDISON COMPANY
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(Res t art)
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(Three Mile. Island Nuclear
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Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of Further Discovery Requests and Interrogatories by Intervenor-Lewis dated February 14. 1980, which was hand delivered to Licensee at Three Mile Island Observation Center, Middletown, Pennsylvania, on February 14, 1980 were served upon those pertans on the attached Service List by deposit in the United States mail, postage paid, this 15th day of February, 1980.
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m ohn F. Wilson Dated:
February 15, 1980 9
9
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE
.0MIC SAFETY AND LICENSING BOARD 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
)
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
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Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin Counq 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 Of.fice of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township Washington, D.C.
20555 T.M.I. 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.
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 Environnental Coalition on Nuclear Power Mechanicsburg, Pennsylvania 17055 433 Orlando Avenue State College, Pennsylvania 16801 Holly S. Keck Legislation Chairman Marvin I. Lewis
- Anti-Nuclear Group Representing 6504 Bradford Terrace York Philadelphia, Pennsylvania 19149 245 West 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 & 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.
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