ML20141N481
| ML20141N481 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 11/12/1985 |
| From: | Karatsanos M UNDERWRITERS ADJUSTING CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20141N476 | List: |
| References | |
| 033-0BD171, 33-BD171, NUDOCS 8603060439 | |
| Download: ML20141N481 (5) | |
Text
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Underwriters Adjusting Company PO. Box 27369 MJwaukee. Wisconsin 53227 Telephoce: (414) 5417222 November 12, 1985 Office of Nuclear Reactor Regulation United States Nuclear Regulatory Coc: mission Washington DC 20555 Attn: Harold R. Denton, Chief l
RE: 6ur Principal: Dresser Industries. Inc.
Claimant:
Dairyland Power Cooperative-lacrosse Boiling Water Heactor Our File:
033-0BD171 D/L:
January 1980
Dear Mr. Denton:
The above matter is now in litigation filed in IaCrosse, WI, the location of the aforementioned claimant. Apparently your department is aware of this development.
The claim allegedly involves damages to a boiler in the amount of
$2,672,865 21.
It is possible that your agency has information on this matter.
Please send us what records you poscess with a bill for processing our request.
If you cannot release any records without a subpoena or other legal action, ve ask that we advised about that.
We look forwird to hearing from you. Our telephone number is 41h-Shl-7222.
Thank you for your expected cooperation.
Very truly yours,
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Michael D. Karatsanos Senior Ad, juster MDK:mo Encl.
P.S.
Attached is some background on this alleged loss.
CC:
U.S.N.R.C.
I Attn John 7aolinski CC:
U.S.N.R.C.
Attn llazel Cmith l
t.
18.
That pursuant to law and subrogation assignments by Dairyland Power Cooperative to the plaintiff " insurers", the plaintiff " insurers" have a claim against the defendants for
$2,647,865.21.
FIRST CAUSE OF ACTION 19.
Reallege and incorporate herein paragraphs 1 through 10.
20.
That Stanley Consultants, Inc., had the overall engineering contract to provide engineering services for the construction and operation of an estimated $120,000,000.00 electrical generating plant for Dairyland Power Cooperative and in the course of providing said engineering services, was negligent in, among other thinos, the design, selection of materials, and supervision services provided by them.
21.
That Newtron, Inc., was negligent in regard to the material and services.provided by it for the aforementioned power plant being constructed for Dairyland Power Cooperative.
22.
That the defendants, Dresser Industries, Inc., and Rockwell International, were negligent in, among other things, the design, manufacturing, warning and sale of valves and other products used in the construction of the aforementioned power plant.
23.
That Electronics Corporation of America was negligent 'in, among other things, the design and manufacturing of the fuel management power supply for the aforementioned power plant.
24.
That the defendant, Wismer and Decker Contracting, did 8
electrical and construction work at the aforementioned power plant I and was negligent in, among other things, the performance of said work and the provision of materials.
25.
That the defendant, Riley Stoker Corporation, was negligent in, among other things, the selection, sale and installation of certain valves.
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26 That the negligence of each of the non-insurance company defendants was an actual and proximate cause of the aforementioned damages sustained by the plaintiffs in the amount of at least
$2,647,865.21, and that all defendants are jointly and severally liable to the plaintiffs for said damages.
SECOND CAUSE OF ACTION 27.
Reallege and incorporate herein paragraphs 1 through 26, 28 That the defendants, Stanley consultants, Inc., Newtron, Inc., Dresser Industries, Inc., Rockwell International, Electronics Corporation of America, Wismer and Becker Contracting, and Riley Stoker Corporation, did provide dangerous and defective products to the plaintiff which products were in substantially the same condition at the time they reached the ultimate consumer as they were in when first manufactured, and that said dangerous and defective products are thetroximate cause of the aforementioned damaans sustained by the plaintiffs.
29.
That the non-insurance company defendants are in the business of manufacturing, selling, and providing products for the use in the construction and operation of, among other things, boilers and that such business of the individual non-inuurance company defendants is not on an isolated or infrequent basis.
30.
That the aforementioned dangerous and defective products were defective when they left the possession and control of the non-insurance company defendants.
31 That as a result of the plaintiff sustaining the aforementioned damage because of the defects in the products manufactured sold, distributed and used by the individual, non-insurance defendants, the plaintiffs sustained the aforementioned damages for which all defendants are jointly and severally liable.
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s WHEREFORE, the plaintiffs demand judgment against the defendants, jointly and severally, in the amount f $2,647,865.21, plus their costs and disbursements in this action, and f5r such other and further relief as the Court may deem just and equitable.
Dated this.3/ # day ot August, 1985.
MEAGHER, GEER, MARKHAM, ANDERSON ADAMSON, FLASKAMP & BRENNAN f By:*
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W. DP F..asfettfnp
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2250 T.D.S. Center
(
80 South Eighth Street
, Minneapolis, Minnesota 55402 Attorneys for Plaintiffs MCDONALD, F
- RICK, EDER & SMYTH By:
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-k Thomas M.
FitzpRtrick 505 King Street, Suite 200 P.O.
Box 1567 La Crosse, Wisconsin 54602-1567 Attorneys for Plaintiffs 4
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