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{{#Wiki_filter:-                                -
{{#Wiki_filter:-
ypED CORRESPONDN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Metter of                           )
ypED CORRESPONDN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Metter of
METROPOLITAN EDISON COMPANY                )                                           g
)
                                                )      Docket     No. 50-289 [*-
Docket No. 50-289 [*-
(Restart)
METROPOLITAN EDISON COMPANY
(Three Mile Island Nuclear               )                             DCOG*             $
)
Station, Unit No.1)                                             k          W
g (Restart)
                                                )
)
2     p,\Y 13 ESO > )r
(Three Mile Island Nuclear
{     pc3 ct es 9mtm4t'r i pgg-c, & kr.ic     .
)
                                                                                ' gor.th TMIA'S FOLLOW-UP INTERROGATORIES               ,b                 $
DCOG*
TO LICENSEE                           ,      g\
p,\\Y 13 ESO > )r W
Station, Unit No.1)
)
k 2
{
pc3 ct es 9mtm t'r i pgg-c, & kr.ic 4
' gor.th TMIA'S FOLLOW-UP INTERROGATORIES
,b TO LICENSEE g\\
These follow-up interrogatories are based upon the deposition of Diane Kay Gee. The signed deposition was filed with the offices of TMIA's counsel on May 6,1980. Accordingly, these follow-up interrogatories are within the time allowed for such interrogatories. All the information requested in these inter-rogatories is related to pages 8, 9 and 10 of her deposition.
These follow-up interrogatories are based upon the deposition of Diane Kay Gee. The signed deposition was filed with the offices of TMIA's counsel on May 6,1980. Accordingly, these follow-up interrogatories are within the time allowed for such interrogatories. All the information requested in these inter-rogatories is related to pages 8, 9 and 10 of her deposition.
: 1. Please supply all documentation in the Licensee's possession related to the cracking of pipes in the borated water system at TMI-1.
1.
: 2. Did Licensee determine the cause of the cracking in the borated water system?
Please supply all documentation in the Licensee's possession related to the cracking of pipes in the borated water system at TMI-1.
: 3. If so:
2.
: a. what was the cause;
Did Licensee determine the cause of the cracking in the borated water system?
: b. who concluded that this was the cause?
3.
: 4. Did any individual employed by or under contract with Licensee disagree with the conclusions reached as to the cause of the cracking?
If so:
a.
what was the cause; b.
who concluded that this was the cause?
4.
Did any individual employed by or under contract with Licensee disagree with the conclusions reached as to the cause of the cracking?
(80,06160lgI i
(80,06160lgI i
: 5. If so:
 
(a) supply the name, address and present place of employment of such individual;                                                 !
5.
(b) supply a copy of any document reflecting disagreement with i
If so:
(a) supply the name, address and present place of employment of such individual; (b) supply a copy of any document reflecting disagreement with i
the conclusions reached.
the conclusions reached.
: 6. Did Terry Mackey take part in reviewing the cracking problem?
6.
: 7. If so, what was his job function in connection with the review of     j the problem?
Did Terry Mackey take part in reviewing the cracking problem?
: 8. With respect to the reorganization referred to at the bottom of page 10 of the deposition, why did Licensee initiate such a reorganization?
7.
: 9. Was Licensee dissatisfied with Mr. Mackey's performance?
If so, what was his job function in connection with the review of j
the problem?
8.
With respect to the reorganization referred to at the bottom of page 10 of the deposition, why did Licensee initiate such a reorganization?
9.
Was Licensee dissatisfied with Mr. Mackey's performance?
: 10. If so:
: 10. If so:
(a) what actions of Mr. Mackey did the Licensee take exception to:
(a) what actions of Mr. Mackey did the Licensee take exception to:
(b) was Mr. Mackey ever reprimanded for the manner in which he was performing his work; (c) was the reorganization a deaction of Mr. Mackey?
(b) was Mr. Mackey ever reprimanded for the manner in which he was performing his work; (c) was the reorganization a deaction of Mr. Mackey?
Respectfully submitted, WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.
Respectfully submitted, WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.
By:         '
h By:
h Theodore A. Adler
/
                                                    /
Theodore A. Adler P. O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 Dated: May 13,1980 i
P . O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 Dated: May 13,1980 i


Eg.'.m_a c?P.nESPcnENc3 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, to be placed in the United States mail, first-class, postage prepaid, addressed to the persons listed below:
Eg.'.m_a c?P.nESPcnENc3 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, to be placed in the United States mail, first-class, postage 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                                                 g 5000 Hermitage Drive                         b       U0CD20 C''W       I;\
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 g
Y,.
5000 Hermitage Drive b
Raleigh, NC 27612                          ~
U0CD20 I;\\
c;. MAY 131920 >
Raleigh, NC 27612 C''W Y,.
George F. Trowbridge, Esquire              >    Office of ge g3c.y.
~
Shaw, Pittman, Potts & Trowbridge               DMeta Q,g,           /0 1800 M Street, N.W.                           1        #'''"4 Washington, DC 20006                             %                Y Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 g /&
c;.
                                                    /     Theodore A. Adler Dated: May 13,1980 l
MAY 131920 >
Office of ge g3c.y.
George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge DMeta Q,g,
/0 1
#'''"4 1800 M Street, N.W.
Washington, DC 20006 Y
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 g /&
/
Theodore A. Adler Dated: May 13,1980 l
l b}}
l b}}

Latest revision as of 19:48, 31 December 2024

Followup Interrogatories Directed to Licensee.Requests Documentation & Causes of Pipes Cracking in Borated Water Sys.Certificate of Svc Encl.Related Correspondence
ML19323H757
Person / Time
Site: Crane 
Issue date: 05/13/1980
From: Adler T
THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:
METROPOLITAN EDISON CO.
References
NUDOCS 8006160151
Download: ML19323H757 (3)
v • d • e


Text

-

ypED CORRESPONDN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Metter of

)

Docket No. 50-289 [*-

METROPOLITAN EDISON COMPANY

)

g (Restart)

)

(Three Mile Island Nuclear

)

DCOG*

p,\\Y 13 ESO > )r W

Station, Unit No.1)

)

k 2

{

pc3 ct es 9mtm t'r i pgg-c, & kr.ic 4

' gor.th TMIA'S FOLLOW-UP INTERROGATORIES

,b TO LICENSEE g\\

These follow-up interrogatories are based upon the deposition of Diane Kay Gee. The signed deposition was filed with the offices of TMIA's counsel on May 6,1980. Accordingly, these follow-up interrogatories are within the time allowed for such interrogatories. All the information requested in these inter-rogatories is related to pages 8, 9 and 10 of her deposition.

1.

Please supply all documentation in the Licensee's possession related to the cracking of pipes in the borated water system at TMI-1.

2.

Did Licensee determine the cause of the cracking in the borated water system?

3.

If so:

a.

what was the cause; b.

who concluded that this was the cause?

4.

Did any individual employed by or under contract with Licensee disagree with the conclusions reached as to the cause of the cracking?

(80,06160lgI i

5.

If so:

(a) supply the name, address and present place of employment of such individual; (b) supply a copy of any document reflecting disagreement with i

the conclusions reached.

6.

Did Terry Mackey take part in reviewing the cracking problem?

7.

If so, what was his job function in connection with the review of j

the problem?

8.

With respect to the reorganization referred to at the bottom of page 10 of the deposition, why did Licensee initiate such a reorganization?

9.

Was Licensee dissatisfied with Mr. Mackey's performance?

10. If so:

(a) what actions of Mr. Mackey did the Licensee take exception to:

(b) was Mr. Mackey ever reprimanded for the manner in which he was performing his work; (c) was the reorganization a deaction of Mr. Mackey?

Respectfully submitted, WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.

h By:

/

Theodore A. Adler P. O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 Dated: May 13,1980 i

Eg.'.m_a c?P.nESPcnENc3 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, to be placed in the United States mail, first-class, postage 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 g

5000 Hermitage Drive b

U0CD20 I;\\

Raleigh, NC 27612 CW Y,.

~

c;.

MAY 131920 >

Office of ge g3c.y.

George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge DMeta Q,g,

/0 1

  1. "4 1800 M Street, N.W.

Washington, DC 20006 Y

Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 g /&

/

Theodore A. Adler Dated: May 13,1980 l

l b

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