ML19330B217

Response to Second Set of Interrogatories.Questions Preheater Role on Filter Sys as Described in Safety Evaluation & Restart Repts.Certificate of Svc Encl

ML19330B217
Person / Time
Site:	Crane
Issue date:	07/16/1980
From:	Lewis M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-SP, NUDOCS 8007310143
Download: ML19330B217 (2)

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7 UNITED STATES OF AMERICA s

NUCLEAR REGULATORY COMMISSION f,

g 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD._

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JUL 2 81980

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In the matter of 1

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METROPOLITAN EDISON CO.TMIf1 3

Docket No 50-289

-,, om, ANSEER TO SECOND SET 03. INTERROGATORIES OF MARVIN I. LEWIS. 6 0

G:ncral interrogatories:

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Ms Swartz's letter of 7 July says to limit my response N

to this interrogatary to the SER only. At this point, I plan to uct only those parts of th SER which are referred to #

in ny, Licensee's, or Staff's Interrogatories abuut the gER.

2. Same answer as #1 except I won't really have an I examination l

P an developed until 1,he date required by the Board.

3.

My interrogatories sent out 6-30-80 do exactly what is asked l

for in this Interrogatory. There are aldo parts in the

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l Rastart Report which may be deficient, but I am still researchig that' question.

It will all be submitted in a timely manner.

Spooific Interrogatories:

1. I am not sure after being in this proceedure whether ay number l

of. filters can do th4 iob of protecting the haalth and safety of the public in an adequat. manner.

The reasons are that I have not cocn the Staff gf or licensee attack this problem in any manner.

There fore, thre cannot be any documentation except an absence of documentation to.-which 'I referred-in my Interrogatories on th e SER.

2. Preheaters may not solve some basic problems in the filter l

cyotem. These were referred to in my submittal on the SER 6-30-80.

Again, I have to admit that a fully developed answer to this Intorrogetory must await respor m a and omplete answerd to my SER Intorro ptories.

I knos *nat

.is a unds like I am throwing tho ba1L back in you. court,,.but I eal'v was. hoping for a l

moro.de finitive SERcwhich would al oted-me toanswer these l

quoctions appropriately and gully.

3. I am not:sure because that cthe SER and the Restart Report have l

not given me enough information.to come to th conclusion that pr heaters are unnecessary.~I reall'y think tht preheaters'should not be needed if the design is adequate, but not3akng in the Re tart 3

s Ropert nor theSER suggests that ta design is adequate. -

9 c, 4.

Which Order Items 4 and Sl Afe you referring to August 97-

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.. j; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BO

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i In the Matter of

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METROPOLITAN EDISON

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COMPANY, et al.,

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Docket No. 50-289

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(Restart)

(Three Mile Island

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Nuclear Station, Unit

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No. 1)

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l CERTIFICATE OF SERVICE herebv certifv that a ency

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• Secretary of the Commission ATTN:

Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Wa.whngton, D.C.

20555 Ivan W.

Smith, Esquire

• Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Dr. Linda W.

Little 5000 Hermitage Drive Raleiegh, North Carolina 27612 George F. Trowbridge,' Esquire

• Shaw, Pittman, Potts & Trowbridge 1800 "M" Street, N.W.

v[h Washington, D.C.

20006 3 - [/

• James Tourtellotte, Esquire 5

, Office of the Executive Legal Director 7

U.S. Nuclear Regulatory Commission Washington, D.C.

20555

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