ML19327A585
| ML19327A585 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/26/1980 |
| From: | Widoff M THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19327A583 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8008060420 | |
| Download: ML19327A585 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION Offlesetthefaeretny b
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y !- y, 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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TMIA'S SUPPLEMENT ANSWER TO LICENSEE'S INTERROGATORY 5-2(c),
Pursuant to 10 C.F.R. 2.740(E) (2) (ii), which states:
(a) party is under a duty seasonably to amend a prior response if he obtains information upon the basis of which... he knows that the response though correct when made is no longer true and the circumstances are such that a failure to amend the response is in substance or knowing conceal-
- ment, TMIA now supplements its response to Interrogatory 5-2(c).
Interrogatory 5-2 Identify every occasion on which TMIA contends that Met-Ed " negligently
... (or) wilfully violated NRC regulations concerning the safe operation cf...
Unit #2... in that it... deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment cf the integrity of the nuclear facility itself."
- a. Define "necessary maintenance and repairs" as that term is used in the allegation, g008060.hO
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- b. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.
- c. Identify all 2ccuments containing any evidence or infermation relating to or bearir.g upon the allegation,
- d. Identify atl persons having any information or knowledge supporting l
or relating to the allegation.
Response 5-2(c)
TMIA has repeatedly notified Licensee of the fact that becc.use of limited temporal and financial resources, TMIA has limited the scope of its search to Unit 1. That remains true today. TMIA coes not have the resources to inves-tigate TMI-2. However, TMIA will rely on the NRC's Office of Investigation and Enforcement's '! Investigation Report Number 50-320/79-10." Of particular importance are items 1, 4(A), 6, 9 and 11. These items will be used by TMIA to illustrate Licensee's " course of conduct" outlined in Revised Contention 5 at Unit 1.
Respectfully submitted, WIDOFF,. EAGER, SELKOWITZ & ADLER, P.C.
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I By:
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Mark P. Wideff 6
P. O Box 1547 Ha isburg, PA 17105 (717) 763-1383 Dated: July 26, 1980
s CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document, TMIA's Supplement Answer To Licensee's Interrogatory 5-2(c), to be placed in the United States mail, first-class, pestage prepaid, addressed to the persons listed below:
Ivan W. Smith, Chairman Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 37830 Dr. Linda W. Little 5000 Hermitage Drive Raleigh, NC 27612 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, DC 20006 Docketing and Service Section U.S. Nue1. ear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Ccmmission Washington, DC 20555 Af
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Marld P. Witoff' l
Dated: Ju1y 26,1980 l