ML20083J872
| ML20083J872 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/03/1984 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML20083J865 | List: |
| References | |
| NUDOCS 8401050459 | |
| Download: ML20083J872 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKETED uur BEFORE THE ATOMIC SAFETY AND LICENSING BOARD to JMl-4 R2 58 In the Matter of
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SQghor er ucRt:Ai8Jisc~f SEiw METROPOLITAN EDISON COMPANY
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Docket No.
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(Steam Generator Nbp41r )
(Three Mile Island Nuclear
)
Station, Unit 1)
)
TMIA RESPONSE TO LICENSEE REQUEST FOR PRODUCTION OF DOCUMENTS Except in those few instances where otherwise noted, the answers to the attached interrogatories are based on Licensee and NRC documents which concern the subject steam generator tubes failures and repairs.
Since all 7icensee documents are already in the possession of the Licensee, and all NRC documents are likely in Licensee's possesion, or if not, can be located in the public document room, it would be unnecessary, burdensome, and improper to require TMIA to attempt to produce these documents, and for all contentions other than TMIA Contention 1.b, for which documents are supplied, TMIA objects to this request for documents.
As to the McGraw-Hill Dictionary of Scientific and Technical Terms and Knott's The Fundamentals of Fracture Mechanic, referred to in response to Interrogatories relating to Contentions 1.d and 2.c, TMIA is not is possession of these documents.
Respectfully submitted, By:
Joanne Doroshow Louise Bradford January 3, 1984 TMI Alert 8401050459 840103 PDR ADOCK 05000289 Q
DOC 1MEMTS STTPPLIED IM RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS The following documents are supplied to Licensee:
September 19, 1982 memo to Ray Fraley from Paul Shewman; Re:
SBLOCA by SG Tube Rupture in TMI-1 September 30, 1982 memo to D. Moeller from Richard Major: Re: MEMO SHEUMON TO FRALEY DATED SEPTEMBER 19, 1982, RE: SBLOCA BY SG TUBE RUPTURE IN TMI-1.
March 23, 1983 letter from Chairman Edward J. Markey to Honorable Nunzio Palladino.
February 18, 1982 POLICY ISSUE, SECY-82-72, to The Commissioners from William Dirks; Re: OVERALL STEAM GENF.RATOR PROGRAM.
00LKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 JAN -4 Pl2:58 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LFFICE OF SECRGAl In the Matter of
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C0CXf.itt4G & SEPVifs BRANCH
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
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(Steam Generator Repair)
(Three Mile Island Nuclear
)
S tation, Unit 1)
)
AFFIDAVIT OF JOANNE DOROSHOW I, Joanne Doroshow, being first duly sworn, deposes and says that:
1.
I am one of two volunteer members of Three Mile Island Alert, Inc., who represent that organization as an intervening party in the above-captioned action.
2.
I have read the foregoing responses to interrogatories, and the same are true to the best of my knowledge.
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DATED: January /, 1989 OANNE DOROSHOW i v2.L Sworn and subscribed before me on this day of January, 1984.
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g64 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00tKETEC U3tBC B5 FORE THE COMMISSION
'84 JMi-4 P12 58 In the Matter of
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FILE OF SELRt.7/
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C0CKEiltiG & SEPVia METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 BRANCH
)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the attached TMIA RESPONSE TO LICENSEE INTERROGATORIES AND TMIA RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, dated January 3, 1984, were served this 4th day of January,1984, by deposit in the U.S.
Mail, first class, postage prepaid, or hand delivered, to those on the attached service list, i
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w1 JOANNE DOROSHOW v
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION s
Before the Atomic Safety and Licensing Board In the Matter of
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METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
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ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
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SERVICE LIST
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Sheldon J. Wolfe>
T Administrative Judge Chairman, Atomic Safety and N
Licensing Board U.S.
Nuclear Regulatory
.Commis s' ion i
D6cketing and Service Section Washington, D.C.
20555 Office of the Secretary U.S. Nuclear Regulatory Commission Dr. David L.
Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Professor of Nuclear Engineering George F. Trowbridge, Esq.
University of Arizona Shaw, Pittman, Potts & Trowbridge Tucson, Arizona 85271 1900 M St.,
N.W.
Washington, D.C.
20036 Dr. James C.
Lamb, III Administrative Judge Jane Lee Atomic Safety and Licensing' Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill, North Carolina 27514 Norman Aamodt Richard J.
Rawson, Esq.
R.
D.
5, Box 428 X
Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director a
U.S.
Nuclear Regulatory Commission Washington, D.C.
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