ML20196D373
| ML20196D373 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/03/1988 |
| From: | Skolnick F SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, TMI-2 & PEACH BOTTOM INTERVENORS |
| To: | GENERAL PUBLIC UTILITIES CORP. |
| References | |
| CON-#188-5584 OLA, NUDOCS 8802170090 | |
| Download: ML20196D373 (24) | |
Text
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'e UNITED STATES OF AHERICA NUCIIAR REGUIATORY C0tHISSION J' I
- hf;.,' BEFORE THE ATWIC SAFEIY AND LICENSING BOARD vhg[0
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In the Matter of )
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GPU Nuclear Corporation Three Mile Island Nuclear Station,
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% FEB 1150-320 9y7:13 Docket No.
Unit 2 ) (Dispossbo& Accident
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' SVA/IMIA'S ItTIERROGATORIES AND REQUEST FOR PRODUCTION OF DOCittENTS TO GPU NUCLEAR CORPORATION
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Pursuant to 10 C.F.R. SS 2.74b and 2.741 and the Atanic Safety and Licensing Board's " Manorandun and Order ( Memoria11 zing Special Prehearing Conference; J
Ruling on Contentions Scheduling )" of January 5th 1988, SVA/ INIA hereby requests that GPU Nuclear Corporation (GPU) answer in writing and under oath or affirmation, each of the following interrogatories separately and fully, and produce and permit inspection and copying of the original or best copy of all docunents identified in the responses to interrogatories below. Under the Ccrmission's Rules of Practice, responses to these interrogatories must be served within 14 days after service of the interrogatories, s
These interrogatories are intended to be continuing in nature, and the answers should pranptly be supplanented or amended as appropriate, pursuant to 10 C.F.R.
S 2.740 (e), should GPU or any individual acting on their behalf obtain any new or differing information responsive to these interrogatories.
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The request for production of docunents is also continuing in nature and GPU aust produce immediately any additional docunents they, or any individual l
8802170090 880203 PDR ADOCK 05000320 G PDR DSo3
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acting on their behalf, obtain which are responsive to the request, in accordance with the provisions of 10 C.F.R. S 2.740 (e).
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. GENERAL INIT.RROGA10 RIES
- 1. State the name, precent or last known address, present or last known errployer, professional and educational qualifications for the following persons: ,
I 1
a) Those persons who attended meetings with the NRC staff "to discuss itans of l information provided, to seek new infonnation fran the Licensee that might be needed for an adequate assessment," (EIS threg 0683 Supplanent #2, Final Report June 1987 P. ix}.
b) Those persons who evaluated the bids fran the vendors for the evaporator, and who chose the vendor to deliver the evaporator. l c) All those persons involved in evaluating the disposal option.
- 2. Identify all camunications between the Licensee and the NRC Staff concerning the evaluation and. search for new infonnation made by the NRC prior to the publication of the EIS, Supplement #2, June 1987.
- 3. Identify all Technical Specifications relevant to the disposal of the water.
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- SPECIFIC IlfERR0GATORIES_
- 1. If " the public perceptior that water is uniquely hazardous..." was a primary consideration in the selection process of the disposal of the water, state the basis upon which GPUN decided that evaporation of the water was more popular or acceptab}e than any other method of disposal?
- 2. Describe the method by which GPUN determined the public's opinion concerning the disposal of the Accident Generated Water (AGW) prier to choosing the evapora-tion method.
- 3. Provide the architectural and engineering plans for the evaporator chosen to dispose the AGW.
4 Identify the vendor chosen to supply the evaporator, a) Describe the prior experience of the vendor with evaporators.
b) Identify the sub-contractors who will be involved in either construction of the evaporator, codifications, establishnent on site or maintenance.
- 5. Are there any cross stockholders between GPU Nuclear and any of the named above in #3 and #4? Identify then.
- 6. Describe specific criteria used for choosing the evaporator.
- 7. Describe changes, additions and/or removals needed to be made to the evaporator so that it can operate in an open cycle. What is the. cost of these nodifications ? Describe the purpose of each emponent which is added, modified or renoved. State the basis for all modifications.
- 8. Describe the previous experience which the Licensee and vendor have in making the m difications to the evaporator so that it will operate in an open cycle.
- 9. Describe the tests to be undertaken prior to use to damnstrate the efficiency of the evaporator in an open cycle mde.
- 10. If the chosen vendor would becane inselvent, how wculd this affect:
a) evaporator services b) solidification services
- 11. GPU Proposal P. 28 List those considerations for using the evaporator for the production of low concentrated borated water. How will these considerations affect:
a) modifications to be made to the evaporator b) the efficiency of the evaporator to operate and renove contaminants in the water Wat were the preliminary investigations undertaken tofind how flexible the systens were?
- 12. Explain the design and construction of the concrete pad.
- 13. Describe how the evaporator will be tied in with:
a) the holding tanks for the AGW ,
b) the Epicor/SDS systan.
Describe dimensions and placanent of pipes, shut off valves, safety systans, and additional tanks.
- 14. khat will be the criteria of selection for operations staff. Describe the required professional background for staff involved in:
a) installation of the evaporator b) maintenance of the evaporator c) operation of the evaporator d) monitoring of the influent and effluent of the evaporator
- 15. How many staff will be involved with:
a) installation b) maintenance c) operation d) monitoring
- 16. How often will a sample be drawn from the influent to the evaporator?
a) Frcm where will the sample be drawn?
b) khat will be the quantity of the sample drawn?
c) khat will be the professional background of the person drawing the sample?
d) How will the sample be prepared for analysis?
e) khere will the sample be analyzed?
f) How long will it take to receive the results of the sample analysis?
g) Will the agency or person responsible for analysis have the equignent capability to detect the full range of radioactive and non-radioactive substances expected to be present in the water?
h) List the radioactive substances and non-radioactive substances which the agency will be capable of measuring.
- 17. khat will be the feed rate to the chosen evaporator?
Under what circunstances wculd this feed rate be:
a) increased b) decreased c) stopped
t 18.
a) How will the heat source be provided and maintained to the contents of the evaporator?
b) To what temperature will the water be heated?
c) What is the optimum tenperature for efficient operation of the evaporator?
State the basis for this determination.
d) What is the temperatere Aich would cause the vaporization of those radio-nuclides liste1 on "Estirrated Average Concentration of Radionuclides Potentially Present in the TMI-2 water for Evaporation"? [ F.R. Standeferer 2/26/87 - presented to the Citizen's Advisory Panel.]
- 19. What is the form - gas, solid, particulate - of each of the contents of the AGW?
a) What is the total particulate content?
- 20. Tables 2 -3 through 2 - 8 in GPU Proposal are not camplete for all radio-isotopes in the water. Identify the values for all radioisotopes expected to be present in the water. Where the radioisotopes are expected but not detected, list the lower level of detectability.
- 21. If more recent sample analyses than the above are available, provide these to the Intervenor.
- 22. For the samples analyzed, state the following:
a) method of procuranent of sample b) quality of sample drawn c) Upon what basis isit assumed that these samples are representative of the total contents of each location ( for both radioactive and non-radioactive substances)?
d) How was the sample prepared for analysis?
e) Who analyzed the sample?
- 23. State which of these sample (s) originated in the reactor core at a time when boron concentration was at its highest.
- 24. What is the total particulate content of the AGW in each location at the f
! end of clean-up and after processing through Epicor/SDS?
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- 25. What is the total gaseous content of the AGW in each location at the end of clean-up and after processing through Epicor/SDS?
- 26. What is the total solids content of the AGW in each location at the end of clean-up and after processing through the Epicor II/SDS?
- 27. Did GPU receive information about the core inventory of tritim following the accident at any time since the original estimate was made in the original EIS?
If "yes",
a) State the information received b) State the source of the information
- 28. If the influent is found to exceed the acceptable level for release, explain the procedure for dealing with this, and in particular, state how the water will be made acceptable for the evaporator. State the basis for the ass m ption that 1% of the particulates in the influent to an evaporator is released when the evaporator operates in an open cycle.
- 29. Would the presence of non-radioactive substances affect the ability of radionuclides to vaporize? Provide the basis for ycur response.
- 30. Describe monitoring features and their function on the evaporator.
a) Which of these features have been added to the evaporator to enable it to operate in an open cycle?
b) Which radioisotopes and in which form, will these monitor (s) be able to detect?
c)Descrite any tests undertaken to prove the efficiency of these conitors when used in an evaporator operating in an open cycle.
- 31. Describe the carry-over nonitor and its method of operation.
a) Is the carry-over monitor a detector or a collector of radioisotopes?
b) Has this carry-over monitor been used before on an evaporator operating in an open cycle?
- If "yes, state where and state any tests and results undertaken to prove the efficiency of.the carry-over monitor on an open-cycle evaporator.
- 32. By what mechanism will a smple strem of vapor be pulled?
ii) How often will the dample be pulled?
iii) What quantity of vapor will be p.:11ed for a sample?
iv) State in what manner GPUN will use this saple as a scaling or guide for the operation of the evaporator? ( Mr. Urland, P.26, Citizen's Advisory Panel Meeting for the Decontanination of Unit 2, 2/87) v) Explain "condense it with continuous conductivity probe" - reference as for 32 iv) above and vi;Describethe method for determining the contents of the sample and list the radioisotopes searched for.
33.Describethe type of in-line monitor to be placed, a) khere will the mnitor be placed?
b) What are the lowest levels of detectability of the menitor for all radio-isotopes expected in the water?
%. How will the beta mitting radioisotopes be mnitored? Explain monitor type to be used and the lower level of detectability of the monitor for each beta mitter and frequency of analyses.
- 35. How will the alpha mitting radioisotopes be mnitored? Explain type of conitor to be used and its lower level of detectability for each alpha mitter.
State frequency of analysis to detennine presence of these radioisotopes.
l l 36.
l a) How will the gasecus effluents be measured?
l l b) How often?
c) Where will the analysis be undertaken?
- 37. What height is the stack through which the contminated vapor will be l
emitted into the air?
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l
a) Explain the means by which heat will be applied and manitained to the stack, b) In the event that the heating systs in the stack would fail, what safety measures will be in place?
c) State those parts which will require maintenance on the evaporator and how often each part will require maintenance, d) State the reasons why the parts will require maintenance.
e) State the basis for the claim that the evaporator in an open cycle will operate 75% of the time.
f) What is the life expectancy of the evaporator?
- 39. Citizen's Advisory Panel for the Decontamination of Unit II, 2/87, P.32, Mr. Standerfer, a) Explain "foaming" and how it affects the operation of the evaporator, b) Explain the causes of "foaming".
c) What steps will GPUN take te prevent it.
d) Upon which basis do you detemine that these are the correct steps to take to avoid foaming?
e) Explain how foaming affects the amount of solids rising with the vapor.
- 40. Is there an autcmatic shut dcum on the evaporator?
If "yes", answer the following:
a) Under what ciretrnstances would the automatic shut down go into effect?
b) Will the number of times the evaporator is shut down have an effect on the integrity of the systm? State the basis for your answer.
c) How nuch time lapses between shut down of the evaporator and the stopping of releases through the stack?
- 41. Are there any conditions, at either Unit I or Unit II under which the evaporator would be slut down other than evaporator maintenance or preparing feed batch? If "yes", explain those conditions.
- 42. Will the evaporator syst s be independent of all other plant systes at Unit I and Unit II?
If "no", answer:
a) How will the evaporator system be dependent?
es b) How will GPU/NRC be able to delineate anissions fran the evaporator fran the routine emissions fran Unit I and Unit II?
- 43. Does the selected evaporator have a proven record for dealing with water with this particular chanistry? If "yes", provide this record.
- 44. ht is the capacity of the concentrates receiving tanks?
- 45. ht special procedures will be used for transferring the evaporator bottans fran the concentrates receiving tank to the solidification systen? [ P.33 GPU Proposal).
- 46. Describe: the piping modifications to be made for the transfer of the evaporator bottans to the solidification systan. [ P. 33 GPU Proposall.
- 47. Describe the cement binder to be used.
- 48. Identify the expected amount of solidified waste to be created by the solidification of the evaporator bottans?
State the basis for this expectation.
- 49. State those limitations imposed by the burial ground license on the solidification binder.
- 50. Is there a bituminization process included with the evaporator?
If "yes", answer the following:
a) Is it acceptable to regulations for imnobilization of the evaporator bottans by use of asphalt.
If not, what will replace it?
b) State the modifications which will need to be made.
- 51. Has GPU sought permission fran DER to bury the solidified AGW waste in an on-site industrial land-fill?
- 52. List the chemicals or other additives used in the clean-up since the Accident in 1979 and explain where they were used and their quantities.
- 53. Did GPU consider the corrosive potential which the additien of the chlorine to the water would have on all parts and operation of:
a) Epicor II b) SDS c) evaporator If "yes",
- 1) were tests undertaken? If so, explain the tests and their results.
ii) If "no", explain the basis for the assuuption that no tests were needed.
5!. . List the chemical or other additives which the Licensee forsees it will have to use to achieve putting the plant into Post Defueling Monitored Storage.
- 55. What is the limit for all of the non-radioactive substances present in the water for the releases into:
a) air b) water List the substances and their limits.
- 56. Does any of t:0 non-radioactive substance (s) in the AGW ("base case and achievable") exceed the limit imposed by any permit required for by any govern-ing agency - State, local or Federal - for disposing of the water?
If "no", state the basis for this determination.
If "yes", list the substances and their quantities.
- 57. List those benefits provided by disposal of the water using the evaporation method which no other disposal method can provide.
- 58. If GPU exceeds the low level waste allotments allowed by DOE before the end of clean-up, where will the excess 1cu level waste be held.
?
- 59. Is the restart of Unit 2 a consideration in the selection of the method to dispose of the water?
- 60. Has GPU sought permission frm DER to bury the solidified water in an on-site industrial landfill?
- 61. EIC .18 3.2 Footnote (a)
Provide doc mentation and water analysis results to show that the coxentration for the specified isotopes ( actinim - 227; americium - 241& 242; californim
-249, -250 & -252; curim -231, -243, -244, -245, and -246); neptunium - 237; protrastine -231; plutonim - 238, -239 & -242; thorim - 238 & - 230; and uranim - 232, does not exceed 1% of the total radioactivity.
- 62. What is the decontamination factor of the evaporator? State the basis for this determination.
REQUEST FDR PRCDUCTION OF DOCUMENIS SVA/MIA requests that Licensee respond in writing to this request for production of docments and produce the original or best copy of each of the docunents identified or described in the answers to each of the above interrc,gatories.
Respectfully Suhnitted, f a t\ \ l' 1) lY(
Frances Skolnick
DOCKETED s USNRC M FEB 11 P7.09 DEFINITIONS AND INSIMCTIONS QFFICE T.; ncN 7fg,,
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'1he following definitions are applicable to each interrogatory and are incorporated by reference in each intenogatory. The interrogatories aust be read in the light of these definitions and yotr answers nust be responsive to the interrogatories as so defined.
- 1. "Document": The term doctnent mcans any written, recorded, printed, typed or other graphic matter of any kind or nature, however produced or re-produced, whether sent or received or neither, including drafts or copies bearing meaning, notations or mafKs not found on or in the original, and includes but is not Ifmited to:
(a) all letters or other fonns of correspondence or camunication, including envelopes, notes, telegrams, cables, telex messages, messages (includingreports, notes, notations and mmoranda or or relating to telephone conversations or conferences.)
(b) all memoranda, reports, test results, notes, transcripts, tabulations, studies, lists, ccmparisons, charts, graphs, stmnaries, extracts, statist-ical records, ccmpilations.
(c) all desk calendars, appointment books, diaries (d) all books, articles, booklets, bulletins, notices, instructions, marnals (e) all photographs, microfilms, tapes or other records, punch cards, magnetic tapes, discs, data cells, print-cuts ad other data ecmpilations frcrn which information can be obtained.
(1)
- 2. "cmuunication": Ibe tem "Camunication" means not only oral comunication but also any "documents" (as such term is defined in paragraph 1. above),
whether or not such doc ment or the information contained therein was transmitted by its to any other person.
- 3. "Identify", "Identity", or " Identification":
(A) When used in reference to a natural person, the terms "identify",
"identity", or "identification" seek the following information:
(1) full name; (ii) present or last b u business address; (iii) present or last known business affiliation, and (iv) present or last known business position (including job title and a description of job functions, duties and responsibilities)
(B) When used with reference to any entity other than a natural person, the terms "identity, "identify", or"identification" ,
require:
(i) its full name; (ii) the address of its principle place of business; (iii) the jurisdictico under the laws of which it has been organised or incorporated and the date of such organisation or incorporation, if h u; (iv) the identity of all indi.viduals who acted or who authorised another to act on its behalf in connection with the matters referred to; (v) in the case of a corporation, the names of its directors and principle officers; and (2) i
s (vi) in the case of an entity other than a corporation, the 2dentities of its partners or principles or all individuals sho act on its behalf in comection with matters referred to.
(C) hn i sed in reference to a docment, the terms "identify",
"identity", or "identification" mean to provide the following information:
(i) the nature of the document (e.g. , letter, contract, memorandum) and any other information (i.e., its title, index or file number) which would facilitate in the identific-ation thereof; (ii) its date of preparation; (iii) its present location and identity (as defined in paragraph 3 (A) hereof) of its present custodian or, if its present location and custodian are not known, a description of its last known disposition; (iv) its subject matter cnd substance or, in lieu thereof, annex a legible copy of the docment to the answers of those interrogatories; (v) the identity (as defined in paragraph 3 (A) hereof) of each person who performed any significant furction or had any role in connection therewith (i.e., author, contributor of information, recipimt, etc.) or who has any knowledge; and (vi) if the docment has been destroyed or is otherwise no longer in existence or cannot be fu M, the reasco, if kne, why such doctrent rx) longer exists, the identity (as defined in (3)
. l I
paragraph 3 (A) hereof) of the person responsible for the document no longer being in existence and of its last known custodien.
(vii) the portion or portions of the docunent (whether section(s),
chapter (s), or page(s) upon which GPU relies (D) When used in connection with an oral canunication, the terms "identify", "identity", or "identification" man to provide the following information:
(i) its general nature (i.e., conference, telephonic ccxmunication, etc.);
(ii) the time and place of its occurence; (iii) its subject matter and substance; (iv) the identity (as defined in paragraph 3 (A) hereof) of each person who performed any function or had any role in connection therewith or who had any knowledge thereof; and (v) the identity (as defined in paragraph 3 (B) hereof) of each docunent which refers thereto or which wac used, referred to or prepared in the course or as a result thereof.
(E) When used in comection with a statute, regulation, or any other legal requirement, the terms "identify", "identity", or "identifi-cation" mean to provide the ccruplete legal citation, by section and subsection, or where no such citation exists, any information necessary to facilitate its location.
(4)
- 4. "Describe" or "Description":
(A) When used with respect to any act, action, accounting, activity, audit, practice, process, occurrence, occasion, course of conduct, happening, negotiation, relationship, scheme, econunication, conference, discussion, developnent, service, transaction, instance, incident, or event, the terms "describe" or "description" mean to provide the following information:
(i) its general nature:
(ii) the tine and place thereof; (iii) a chronological account setting forth each element consisted of and what transpired as part thereof; (iv) the identity (as defined in paragraph 3 (A) hereof) of each person who perforned any function or had any role in connection therewith (i.e., speaker, participant, contribu-tor of information, witness, ste.) or who has any knowledge thereofi (v) the identity (as defined in paragraph 3 (B) hereof) of each docunent wY.ch refers thereto or which was used, referred to or pepared in the course or as a result thereof; and (vi) the identity (as defjned in paragraph 3 (C) hereof) of each oral comunication which was a part thereof or or referred thereto, (B) When used in comection with any test data the terms "describe" or "description" mean to provide the following information:
(5)
(i) all calculations, ccmputer printouts and any other docu-mentation used to obtain stated test results, including sequence of testing; (ii) an explanation of its meaning (including the nature, source and meaning of each cwpccent part thereof);
(iii) an explanation of the manner in which it was derived; (iv) the identity (as defined in paragraph 3 (A) hereof) of each person who performed any function with respect thereto; (v) the identity of each document (as defined in paragraph 3 (B) hereof) which refers thereto or which was used, referred referred to or prepared in the course or as a result thereof; and (vi) the identity (as defined in paragraph 3 (C) hereof) of each oral comunication which occurred in the course of the preparation thereof or which referred thereto.
- 5. "Factual Basis": 'Ihc term "factuel basis" means; (A.) set forth each itan of information upon which the allegation, contention, claim or assertion to which it pertains is based, and (B) with respect to each such itan of infonnation identify each person having knowledge thereof and identify and describe (as defined in paragraphs 3 aal 4 hereof) each source thereof, including but not limited to each doctnent oral comunication, act, action, activity, accounting, negotiation, practice, process, occurrence, occasion, course of conduct, happening, relationship, scheme, conference, discussion, developmnt, service, instance, (6)
O incident, event, calculation and ccinputation upon which you rely with respect thereto.
- 6. "Relates to": The term "relates to" or "relating to" when used in connectico with any act, action, activity, accounting, practice, process, occurrence, occasion, course of conduct, contractual provision or document, happening, relationship, schane, conference, discussion, developnent, service, instance, incident, event, etc., means used or occuring or referred to in the preparation thereof, or in the course thereof, or as a consequence thereof, or referring thereto.
- 7. "Person": The term "person" means all natural persons, corporationsy partnerships or other business associations, public authorities, cunicipal corporations, state goverrrnents, local govemnents, all govemnental bodies, and any other legal entities..
Answer by reference to Docunents: Identify each and every docunent 8.
which you claim supports each fact set forth in your answers to the Interrogatories. With / : ect to each answer, identify (as defined in paragraph 3 (C) hereof) the specific docunent, docunents, or portions thereof idsr.t~ ; y page and paragraph tunber within the page, containing the requested information, or attach a copy to the answer hereto.
- 9. For each interrogatory answer, identify each person who participated in the preparation of the answer, and who provided information to you upon which you relied in preparing answer, and precisely what information was provided by each such person.
(7)
cl
- 10. "Licensee": "Licensee" includes Metropolitan Edison Canpany and GPU Nuclear Corporation, and all present and former officers, anployees, agents, and all other persons, engineering or consulting firms or carpanies acting or purporting to act en behalf of Het Ed, GPU tbclear, and/or any kind and all parent and p'redecessor entities.
- 11. "You" means any member or umbers of the NRC staff, its enployees, agents, and all other persons acting or purporting to act on its behalf.
- 12. "State the basis" includes the factual, legal and other bases for the relevant assertion, and includes the terms "factual basis," "identify,"
and "describe" as defined herein.
(8)
includes Metropolitan Edison Cxpany and 10.'%/GRJ" "You br GPU" GPU thelear Corporation, and all present and former officers, anployees, agents, and all other persons, engineering or consulting firms or coupanies acting or purporting to act cm belalf of Met Ed, GPU tbclear, and/or any kind and all parent and predecessor entities.
- 11. "?mC" ' means arry manber or members of the NRC staff, its enployees, agents, and all other persons acting or purporting to act on its bchalf.
- 12. "State the basis" includes the factual, legal and other bases for the relevant assertion, and includes the terms "factual basis," "identify,"
and "describe" as defined herein.
(8)
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00L6ETE0 the. U5NRC Fe b @ 6U19 N N OFFICL Or E Pt! An' 00cKC11Nu a SEiivicf.
BRANCH UNITED STATES OF AMERICA NUCLEAR REGUIATORY CCttfISSION BEFORE THE ATQ41C SAFFIY AND LICENSIt0 BOARD In the Matter of ) Docket No. 50-320-OLA GPU tbelear Corporation f Disposal of Accident-Three Mile Island Ibclear Station, ) Generated Water Unit 2 l t CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "SVA/IMIA'S Interrogatories and Request for Production of Docunents to NRC and to GPU Nuclear were served this 7th day of February,1988 by Way Messenger Service upon the NRC and GPU, and by first class postage prepaid mail on February 8th, to the renainder of i the service list.
t O , , h "C T(uGAD. C Fratres Skolnick i
t SERVICE LIST t
Sheldon J. Wol f e , Chairman John R. McKinstry, Esq.
Administrative Judge Assistant Counsel Atomic Safety and Licensing Commonwealth of Penn.
Board Panel 505 Executive House U.S. Nuclear Regulatory Commission P.O. Box 2357 Washington, D.C . 20555 Harrisburg, Pa. 17120 Glenn O. Bright Thomas A. Ba,ter. Esq.
Administrative Judge Shaw, Pittman, Potts c4 Atomic Safety and Licensing Trowbridge Board Panel 2300 N Street, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20037 Washington, D.C. 20111 Dr. Oscar H. Paris Stephen H. Lewi5 Esq.
Administrative Judge Office of the General Atomic Safety and Licensing Counsel Board Panel U.S. Nuclear Regulatory U.S. Nucl ear Regul a tory Ccani ssi on Commission Washington, D.C. 20555 Washington, DC 20555 Dr. William D. Travers Ms. Vera Stuchinski Dir. Three Mile Island Threo Mile Island alert Cleanup ProJ ec t Directore 315 Peffer Street P.O. Box 311 Harrisburg, Pa. !?102 Middletown, Pa. 17057 Docketing & Services Branch Secretary of the Ccmnission U.S.N.R.C.
Washington,DC 20555.
t
@MW w Frances Skolnick
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