ML19329G109
| ML19329G109 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/18/1980 |
| From: | Adler T THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19329G108 | List: |
| References | |
| NUDOCS 8007140009 | |
| Download: ML19329G109 (4) | |
Text
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ft UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC 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
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USNBC ts JUL 81980 > @
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TMIA'S FOLLOW-UP INTERROGATORIES BP TO LICENSEE A
g (Second Set)
CD These follow-up interrogatories are promulgated pursuant to the Board's Memorandum and Order cf May 5,1980. The information upc,.. which these inter-rogatories are based was discovered on June 9,11,12,14,16,1980 (detailed infra) while reviewing documents supplied by Licensee. Although this information was made available in the latter part of March,1980, thousands of work requests are still being evaluated by TMIA. TMIA's knowledge of the 1:aormation on which the following interrogatories are based was nec acquired until June 9, 11, 12, 14, 16, 1980.
Interrogatory 1 Based on the evaluation cf Work Requests 25166, 24159, 24218, 21857 ar.d 25110 (included in Licensee's Response to TMIA's Interrogatory 5-6) on June 11 and 12,1980, please define the word " purged" as used on the above work requests.
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A.
Who " purged" the above work. equests?
B.
Who has the authority to " purge" a work reque.it?
C.
What criteria are used in " purging" a work request?
D.
What is the status of a work request after " purging"?
E.
Are there other definitions for the word " purged" with respect to work requests?
- 1. If so:
(a) Set forth each definition; (b) Identify how the correct meaning can be discerned from a visual inspection of the work request.
Interrogatory 2 The following requests are based on the information cbtained from TMIA's initial evaluation cf Licensee's response to Interrogatory 5-7 completed June 9, 1980:
A.
Provide all documentation for each work-related accident at Three Mile Island occurring from October 1,1977, to March 30, 1979, involving injury to an employee (s) and/or damage to property.
B.
Provide all documentation of each instance where an employee at TMI has called off sick from October 1,1977, to March 30, 1979.
C.
Provide allinfirmary records for Three Mile Island from October 1, 1977, to March 30, 1979.
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I Interrogatory 3
. Based on the evaluation of Work Request 24511 made on June 16, 1980, please explain what "M. Ross's leak list" is.
A.
Provide a copy of "M. Ross's leak list".
Interrogatory 4 TMIA based this interrogatery on an evaluation of the Maintenance Log (Volume 4 and 5 given in response to TMIA Interrogatory 7-10) on June 14, 1980.
TMIA has identified a significant number of very recently completed work requests, including 16968,19507,19976, 21136, 21894, 22589, 22977 and 26000.
Therefore, TMIA requests that Licensee vpdate its response to TMIA's Interrogatory 5-6 by supplying a computer summary cf all work requests com-pleted from January 1,1980 to date.
Respectfully submitted, WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.
By:
Theodore A. Adler P. O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 Dated: June 18,1980.
C CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document, TMIA's Follow-Up Interrogatories To Licensee (Second Set) to be placed in the United States mail, first-class, postage prepaid, addressed to the persens listed below:
Ivan W. Smith, Chairman Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555
'js Dr. Walter H. Jordan
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g D00%U9 Oak Ridge, TN 37830 uttL a GB0 > 7 Dr. Linda W. Little jul
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5000 Hermitage Drive emee et et Scd Raleigh, NC 27612 Ddd4 E S#
kamh ts George F. Trowbridge, Esquire kot 4' Shaw, Pittman, Potts & Trowbridge 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 l
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Theodore A. Adler Dated: June 18,1980
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