ML19309C101
| ML19309C101 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/22/1980 |
| From: | Widoff M THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19309C076 | List: |
| References | |
| NUDOCS 8004080167 | |
| Download: ML19309C101 (7) | |
Text
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1 P&TED CORRESPONDENC3 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 (Three Mile Island Nuclear (Restart)
Station, Unit No. 1)
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INTERROGATORIES OF INTERVENOR THREE MILE S/
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g ISLAND ALERT, INC. TO LICENSEE 00 ggy,c
$60 Y (Seventh Set) 9g3 39
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g TO:
Ivan W. Smith, Esquire gf Chairman s, Va)
Atomic Safety and Licensing Board Panel
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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.
Provide the social security numbers of the following former employees previously identified in response to Interrogatory (First Set) of TMIA, Inc., No. 28 (Attachments A and C) or otherwise identified by TMIA, Inc. during discovery:
(a)
Thomas Leach (b)
Dale E. Barber 8 0 04 080) f?'
(c)
Randolph F.
Schoedler (d)- William Eddings (e)
Jeffrey S. Summy (f)
Johnny R.
Icard (g)
John J. Murano (h)
Ronald A. Myers (i)
Joseph E. Brenner (j)
Michael N. Grimm (k)
David G.
Labby (1)
Ronald L. Parmer i
(m)
Art J.
Rahm (n)
Lawrence J. Straub (o)
Jeffrey L. Ruth (p)
Carl J. Yeagley (q)
Ronald J. Mondulick (r)
Gary L. Horst (s)
Robert E.
Fenton (t)
Paul M. Baker (u)
Leon A. Laime (v)
Warren R.
Long (w)
Milton W. Johnson (x)
Robert W. Jones (y)
Sidney P. Kline (z)
Richard B.
Fischer (aa) Barry J. Peifer (bb) James C. Baker.
L__
7 2.
Provide a current organizational chart showing the names and functions of those responsible for the functioning and supervision of the following departments at Three Mile Island (Units 1 and 2) which discovery has disclosed play an important and integral role in repair and maintenance functions:
(a) ' Maintenance o
(b)
Operations (c)
Health Physics (d)
Quality Assurance (e)
Engineering (if not considered part of Operations)
Also show to whom the heads of these departments report.
3, Provide a comparable chart for March 28, 1979.
4.
For the five departments. listed in Interrogatory No. 2 provide a complete list of all employees who are now or have been employed in such departments comparable to that provided in response to Interrogatory (First Set) No. 28 5.
For the five departments listed in Interrogatory No. 2
. provide the names, addresses and social security numbers of every employee who has left his employment at Three Mile Island since March 28, 1979.
6 For each former employee of these five departments, provido for inspection copies of all exit interview reports or sheets and/or any other written material relating to the employee's departure.
7.
Provide a computer print-out of all open work orders as of March 28, 1979.
8._
Provide.a computer print-out of the complete maintenance.
record of the following components or systems at. Unit 1:
(a)
CW-P-0001E (b)
CW-V-005A (c)
EG-P-0001A-
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(d)
- FW-J 3
(e)
FW-P-0001A (f)
FW-P-0001B (g)
FW-V (h)
HD-P-001B (i)
HV-V-0014B (j)
MS-V (k)
MV-V
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(1)
NR-P (m)
Q-PL (n)
.RC (o)
RC-P (p)
RM-A (q)
RM-L (r)
Sec
't (s)
TG 9.
Provide for inspection the maintenance log for Unit.1.
10.
Provide all " Administrative Procedures" explaining the use and meaning of the job ticket form and the priority system that has been used or is in use at Three Mile Island for.
categorization of work orders and job tickets - including
- 1016, 1021, 1026, 1027, 1407-1 and provide all written explanations or hand-outs distributed to staff that explain the priority system and any changes made to it since March 28.
11.
Provide a narrative description of how the management and organization of Three Mile Island maintenance, repair and quality assurance functions have been reorganized or changed since March 28, 1979.
12.
Provide the "no-name outage list"as of March 28, 1979 and as of February 22, 1980.
Respectfully submitted, WID F REAGER 97'EnWITZ & ADLER, P.C.
/
By:
Mark V. Widoff p(
Dated:
February 22, 1980
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e Y m ccB?isrc:wicP 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, D.C.
20555 g
Dr. Walter H. Jordan N
081 West Outer Drive COCKETED '
Oak Ridge, Tenn.
37830
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- q FEB 291980 >
Dr. Linda W. Little O 5000 Hermitage Drive Offica of th3 Sr.d.7 J Raleigh, N.C. 27612 Dec22 W$2 hhE p k George F. Trowbridge, Esquire a) Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W. Washington, D.C. 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l ark P. Widoff Dated: February 22, 1980 i 1 l' -v> =}}