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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20148P2031988-04-0404 April 1988 NRC Staff Response to Supplemental Interrogatories from TMI Alert/Susquehanna Valley Alliance.* Related Correspondence ML20150F8851988-03-30030 March 1988 Answers to Sva/Tmi Alert Second Set of Interrogatories to Util.* Submits Responses to Sva/Tmi Alert 880315 Interrogatories.W/Certificate of Svc.Related Correspondence ML20150D0561988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20150D0441988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to Gpu Nuclear.* Related Correspondence ML20149N0461988-02-22022 February 1988 NRC Staff Response to Interrogatories from TMI Alert/Sva.* Responds to Interrogatories Filed by TMI Alert/Sva on 880207.NRC Waived Requirement for Order from Presiding Officer Directing Discovery.Related Correspondence ML20196F1181988-02-22022 February 1988 Responses to NRC Interrogatories.* All Responses Re Disposal of Accident Generated Water by Intervenor F Skolnick. Certificate of Svc Encl.Related Correspondence ML20149M8671988-02-22022 February 1988 Licensee Response to Sva/Tmi Alert Request for Production of Documents.* Documents Re Disposal of accident-generated Water Will Be Made Available for Insp & Copying as Listed. Certificate of Svc Encl.Related Correspondence ML20149M8621988-02-19019 February 1988 Licensee Answers to Sva/Tmi Alert Interrogatories to Gpu Nuclear Corp.* Responds to Sva/Tmi Alert Interrogatories Re Disposal of accident-generated Water.Related Correspondence ML20149K8801988-02-15015 February 1988 Valley Alliance/Tmi Alert Responses to Licensee Interrogatories & Request for Documents.* Info Will Be Provided Upon Availability & Listed Documents Being Sent to Licensee.W/Certificate of Svc ML20196D3731988-02-0303 February 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Util.* Original Documents Identified in Answers to Listed Interrogatories Requested.W/Certificate of Svc.Related Correspondence ML20196D3921988-01-31031 January 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Nrc.* NRC Must Produce Any Addl Documents Responsive to Request.Certificate of Svc Encl.Related Correspondence ML20148U5331988-01-29029 January 1988 Licensee Interrogatories & Request for Production of Documents to TMI Alert & Susquehanna Valley Alliance.* Joint Intervenors Should Produce Original Documents Noted in Interrogatories.W/Certificate of Svc.Related Correspondence ML20235B6151987-09-18018 September 1987 NRC Staff Sixth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories.* Staff Intends to Call C Barus as Rebuttal Witness.W/Certificate of Svc.Related Correspondence ML20214S0551987-06-0202 June 1987 Gpu Nuclear Response to NRC Staff Request for Production of Documents.* Request 1 Overly Broad,Burdensome & of Limited Relevance.Request 2 Vague.Related Correspondence ML20207S5861987-03-18018 March 1987 NRC Staff Response to Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20212N4831987-03-0505 March 1987 Gpu Nuclear Corp Response to NRC Staff Second Request for Documents.* Notes of Interviews Conducted by Stier or Associates & Certificate of Svc Encl.Related Correspondence ML20212K3891987-03-0303 March 1987 NRC Response to Gpu Nuclear Corp Third Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20212F9481987-03-0202 March 1987 Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* NRC Should Produce All Documents Required to Be Identified by Listed Interrogatories.W/Certificate of Svc.Related Correspondence ML20211F5331987-02-19019 February 1987 Gpu Nuclear Corp Response to NRC Second Set of Interrogatories.* Persons Attending 830323 Meeting Re R Parks Public Statement Listed.Certificate of Svc Encl. Related Correspondence ML20211D6811987-02-19019 February 1987 NRC Fifth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Affidavit of MT Masnik Encl.Related Correspondence ML20212R6771987-01-29029 January 1987 NRC Staff Second Set of Interrogatories & Request for Documents to Gpu Nuclear Corporation.* Requests Info on 830323 Meeting W/Bechtel & Transfer or Removal of R Parks. W/Certificate of Svc.Related Correspondence ML20212R6501987-01-27027 January 1987 Gpu Nuclear Corp Third Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20207P7141987-01-13013 January 1987 Gpu Second Request for Production of Documents.* Gpu Requests That NRC Identify Title,General Subj Matter,Date, Author & Reason Why Documents Requested Being Withheld. Related Correspondence ML20207N6721987-01-0909 January 1987 NRC Staff Fourth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N7081987-01-0909 January 1987 Second Supplemental Response of Gpu Nuclear Corp to NRC Staff First Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N6911987-01-0909 January 1987 Third Supplemental Response of Gpu Nuclear Corp to NRC Staff First Set of Interrogatories.* Related Correspondence ML20207L9041987-01-0505 January 1987 NRC Staff Third Supplemental Response to Gpu First Set of Interrogatories & Request for Production of Documents.* MT Masnik & Me Resner 870105 Affidavits & Certificate of Svc Encl.Related Correspondence ML20207C4711986-12-22022 December 1986 Second Supplemental Response to NRC First Set of Interrogatories Re Util Organization & Witnesses.Certificate of Svc Encl.Related Correspondence ML20212D6651986-12-15015 December 1986 NRC Staff Second Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Unexecuted Affidavit of RA Meeks & Certificate of Svc Encl.Related Correspondence ML20211K2771986-11-13013 November 1986 Response to First Request for Production of Documents Re Basis for R Parks Removal from Test Working Group on 830223 & Parks Involvement W/Quiltech Co.Certificate of Svc Encl. Related Correspondence ML20215M9901986-10-29029 October 1986 First Supplemental Response to NRC First Set of Interrogatories Re Suspension of R Parks Employment at Facility Site.W/Certificate of Svc.Related Correspondence ML20211G5101986-10-28028 October 1986 Response to Interrogatories Re Bechtel Oct 1984 Rept, Rept of Bechtel North American Power Corp Re Allegations of Rd Parks & Eh Stier 831116 Rept, TMI-2 Rept-Mgt & Safety Allegations. Related Correspondence ML20215D8681986-10-0909 October 1986 First Request for Production of Seven Categories of Documents Re Basis for R Parks Removal from Testing Working Group on 830223 & Investigation of Parks Involvement W/ Quiltech Co.Related Correspondence ML20215D8781986-10-0909 October 1986 First Set of Interrogatories for Documents Re Identification of Util Employees Providing or Receiving Info Leading to Interrogation of Rd Parks Re Quiltech Co.Related Correspondence ML20215D8821986-10-0909 October 1986 Supplemental Response to Gpu First Set of Interrogatories & First Request for Documents Re Enforcement Action EA-84-137. Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20214R6291986-09-23023 September 1986 Response to Util First Set of Interrogatories & Partial Response to First Request for Production of Documents. Affidavits Encl.Related Correspondence ML20209G1681986-09-0404 September 1986 First Request for Production of Documents Identified in NRC Responses to Listed Interrogatories,Including Interrogatory 1(e) Re Protected Activity Engaged in by Parks Resulting in Alleged Discrimination Against Parks.W/Certificate of Svc ML20209G3181986-09-0404 September 1986 First Set of Interrogatories Re Removal of Rd Parks from Employment.W/Certificate of Svc ML20211E6311986-06-11011 June 1986 First Supplemental Answer to NRC First Interrogatories & Request for Production of Documents to C Husted.Rl Long Notes Produced Indicating Husted Met W/J Herbein on 811005. Related Correspondence ML20211E6601986-06-11011 June 1986 First Supplemental Answers to TMI Alert First Request for Production of Documents & First Interrogatories to C Husted. Rl Long Notes of 820527 Conversation W/Newton Encl.W/ Certificate of Svc. Related Correspondence ML20197C1931986-05-0808 May 1986 Answers to TMI Alert,Inc 860501 Supplemental Interrogatories.Certificate of Svc Encl.Related Correspondence ML20203L6011986-04-28028 April 1986 Responses to TMI Alert First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20141J3171986-04-23023 April 1986 Response to Util First Interrogatories & Request for Production of Documents Re Senior Reactor Operator Licensing Exams.Certificate of Svc Encl.Related Correspondence ML20141J4071986-04-23023 April 1986 Response to Husted First Interrogatories & Request for Production of Documents Re Alleged Cheating During Apr 1981 OL Exams.Certificate of Svc Encl.Related Correspondence ML20155F5471986-04-18018 April 1986 Supplemental Response to NRC Interrogatories 3 & 4 & Request for Production of Documents to Util.Certificate of Svc Encl. Related Correspondence ML20203B4121986-04-15015 April 1986 Response to First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20203B6311986-04-14014 April 1986 Answers to Staff First Interrogatories & Request for Production of Documents.Related Correspondence ML20202G5381986-04-0909 April 1986 First Interrogatories & Request for Production of Documents to TMI Alert Re Apr 1981 Senior Reactor Operator Exam. Certificate of Svc Encl.Related Correspondence ML20202G7361986-04-0909 April 1986 Response to TMI Alert,Inc First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20202G6651986-04-0808 April 1986 C Husted Answers to NRC First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1988-04-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
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- UNITED STATES OF AMERICA %
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' NUCLEAR REGULATORY COMMISSION. f
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O BE10aB Taz iTOM1a SirETr iND t1CENS1NG BoiRD. : 9 m 22 eo "
IN the matter of ) arrM C22232GCN goeS METROPOLITAN EDISON COMPANY ) Docket No. 50-289. , **
(Three Mile Island , No.1) ) {g ?
Intervenor Lewis's FOHRTH SET OF INTERROGATORIES AND.FURTHER DISCOVERY REQUESTS TO NEE NRC STAFF.
D_ipcovery Reouests:
- 1. Please send a copy of NRC Eranslation 628(See letter from '
Varga to all Boards dated 1-24-80 ) in the original' Japanese.)
- 2. Ms Barley is temporarily without a car. She requires a c'opy of the Rog& vin Report. This report was supp)ied previously to intervenors. Intervenor Lewis cannot share his copy due to distance . and due to the fact both people work full time jobs.
Send Ms Barley a copy of the Rogovin Report at Susan Barley 129 Cocoa Hershay PA 17033.
- 3. Intervenor Lfewis wished to provide the Staff with Ms Barley's mailing address so that the Staff may fulfil The Board's Order of 2-13-80 ansix at the Pre Hearing Conf -
erence to ' add Ms Barley's name to the Staff's mailing list in this Docket:
Susan Barley 129 Cocoa Hershey PA 17033.
j Ms Barley requested that her name be added to the taff's , Licensee, and Board mailings only. Ms Barley does not require that she get all the Intervenor l mailings uhless they specifically impinge upon the .
Lewis Contention.
4/ Send the Following documents:
Regulatory Guide 1.52 ANSI 510-1975 8003sloOLLl
g- _
-~_m,
- Intervenor Lowie's F0HRTH SET OF INTERROGATORIES TO NRC STAFP NRC 29. The Status. Report dated 1-11-80 is much greater than the 8 1/2 x 11" size ordered by the Board in its first Prehearing Conference._ Intervenor Lewis does not remember Staff objected to that size at the time Chairman Smith specified it. '
Obviously , the "taff received permission to use other than i 8 1/2 x 11" from the Board. The Staff would not break or i ignore a Board Order unilaterally.
Nonetheless, Intervenor Lewis has se.en no guidance concerning new sizes of paper for submitthis which are now allowed.
d ince Intervenor Lewis has very limited Ililing space, he
- requires to know what sizes of paper to expect from StaII in their filings.
What sizes of paper will staff use in their future filings specifically with reference to Status Reports?
NRC 30. Has some means been promoted for the NRC to obtain anonymous tips from informants as to paactices on the constructinn and maintenance of the TMI#1 facility?
This concern is 44 especially pertinent to the Lewis Contention as the filters and vent header are deep within the facility and any adverse handling or practices would not easily be reported without the threat of anonymous tips.
Please note that the problems 21 Wetinghouse Turbine Cracking (Varga: Knight:BO,16Tx 1,16.) and concrete problems at Wolf Creek and Summer were also brought to light thru anonymous
. tips.
NRC 31.
The letters NRC /TMI 80-028 and Eisenhut:All Power Reactor Licensees -80.01.297 rabe several issues which are explored in the following interrogatories.
. A. What provisions , if any , are presently in place to guarantee that the requirements specified in Eisenhut:All Power Reactor Licensees-80.01.29 can be met?
Answer with specificity for delay and decay tank bottoms, spent charcoal and HEPA filter media pertinent to the Lewis Contention.
B. What guarantees are in place to assure that spent filter media can be moved off site to appropriate low level waste sites? Are LLW sites available now and in the future? -
C. Referring to Kemeny Report ,Page 30, Item 11.
- 3. .
, "Icding filtora in the auxiliary and fuel handling buildings did not p;rform as designed because the charcoal filtering capacity was apparently partially expended due to improper use beforethe accident . Required testing far of filter effectiveness for the fuel hand 14ng building had been waived by the NRC . There were no testing requirements to verify auxiliary building filter effectiveness."
C-1 What was "the improper use" referrei to in the quote above from the Kemeney Connission? Give type of use; dates; who authorized; where written authorizationa , auch as logs, work or job tickets, proper paperwork stored?xxA 8end copies if not ir an eaelly , accessible public reading room of all
- supporting documents referred to in thisxx the answer to tM gggg this and all interro6storio9.7 G@#h C-2 Ehen, why', and how was " required testing for filter E55d effectiveness for the fuel handlin.; building ... waived i gggg by the NRC"? Specify nanes , dates, cend copies of letters E553 and any other pertinent docunentation with youranswer.
hfE[
C-3 Considerin g that there were " no tentin6 requirements E5j$
to verify auxiliary building filter effectivenens",was ci=
ggga thelicenseeopedr$tinginviolationof ICC'R 50 Appendix A F--"
GDC 41 "dystems to control fission products... shall be provided as necessary to reduce...the concentration and quality of fiosien producte releaned to the environmen.tt."
GDC 60 All. <
GDC 61 The fuel storage and handl&ng, radioactive waste, and other cystems which may contain radioactivity shall be designed to asnure adequate safety under normal and postulcted accident conditions. These systetsskill be designed (1) with a capacity to permit appropriate periodic intpection and testing...
(3)with apppopriate containment , confinement and filtering systema."
C-417as the NRC knowingly allowing the Licencee to operate in violation to any GDC?
C-5 Did the /ITRC allow the Licensee to operate without checking the effectiveness of the filter media because there was a problem of three to get rid of the loa Level waste generated in the filtering systems? ras thic c form of re1N1f granted to the Licensee by the XRC to circumvent a LLh disposal probleg?
Has any form of IL;i been refused at any site from TMI? If so, have the intervenors received any notification of said refusal xts and why?
1 4.
NRC 32. Rofor to NRC/TMI 80-020 ; NRC /TMI 80-022 ; and NRC l News Release I-80-26 (Region 1.)
. A. Is the problem described in NRC/E4I 80-020 similar for i units land 27 Have all fan and filter Dousings been checked at both units for compatibility? When , by wh6m, documentations?
B. How will a drop of AB negative pressure requirements Affect t
the ogration of filters and filter housings if at all?
(Engx Leak rates, conddhation transfer to electrical pumps, from the surface ofthe filter housing, and any other pertinent ,
changesinoperatingpar{{eters.) NRC /TMI 80-022.
C. NRC News Release I-80-26 3rd Paragraph. "The releases apparently were caused by radioactive.waterin a water .
purification system ( ion exchanger) seeping past a valve and into piping normally used to carry radioactive gases to a building shautxBx23txxf exhaust and to the plant stack."
Have the filter systems and vent systems been corrected so that this event cannot be repeated at TMI#1?
If so, how so? Provide working drawings and engineering analysis.
If not, when will it be corrected? How will it be corrected?
Provide schedule and program for correcting this deficiency.
NRC'33. Supplemental Views by Members of President's Commission on the Accident at Three Mile Island on Page 12 , Commissioner Pigford states , "Although other components, systems, or features are classed as "non safety related" , they must meet require -
ments appropriate to their operational function."
A. What requirements applied to the filters and vent header
, during the day of the accident at TMI#2? Ylere they met?
Will the same requirements hold for TMI#1 if and when it goes back on line?
NRC 34. Letter Plesset : Aherne 80.02.11 states,e The ACRS believes that its input into this process has been largely ignored by the Commission and is concerned the the ' rush to judgment'on those important matters may result in, at l worst , error and at best inefficient use of resources important to safety." l Has any input from the ACRS been factored into the TMI restart effect? Specifically, of the question of vent headers and filters. If so , provide documentation.
5.
,c' NRC 35.
The anewer to NRC 2 io not responsive; howver, rather than going thru the objection route , Intervenor Lewis resubmits an expanded NRC 2 as NRC 35.
How are the answers in NRC #1 specifically going to help the filters and vent header work conrectly and and adequately in a repeat of March 28 accident at TMI#1? .
i By specifically, cite problem ( leak at pump seal), how discovered (metallurgical examination by MetLab, Mr So and Sa) how corrected (work order , NRC approval, LER #, I&E action #)
and any other facts which would provide assurance that the action was properly grounded on fact and in fact accomplished .
Do this both for vent header and all filters which did not -
operate within expected limits. See NRC 31 C for guidance on which filters to include. Stde and document how this is being done on a continuing basis.
NRC 36.
NRC 10 was objected to as " burden-some and improper. "
It was not meant to be. It is rewritted and resubmitted as NRC 36.
The Licensee has supplied everyone on the Distribution List with his answers to Lewis Interrogatories . The Staff will read (or appropr6 ate S'taffer) the Licensee's answers to Lewis Interrogatories, and answer thef following :
A. Are the Licensee's answer's to Lewis Interrogatories accurate? No opinion on responsiveness is asked.
B. If any of the above answers are not accurate, would the Licensee je,opardi{e the health and safefy of the public by implementing said inaccuracies?
' HRC Ezer 37. The Staff's answer to NRC 8 is not responsive in thatitdoes$$$Igivetimesnorstatethattheyareunavailable.
Intervenor Lewis is not objecting to this answer since he has obtained sufficient times and dates on his and his associate's researches. One question remains:
DoestheStaffagreewiththedatesfndtimesofreleasesreferred to in the Rogovin and Kemeny Reports? In order to reduce the burden , the S aff need only answer for the major document and t
not the Staff reports. However, Intervenor Lewis reserves the right to refer to above mentioned Staff reports in dir( and indirect testimony.
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6.
Intorvanor Lsain's FOURTH SE2 OF INTERROGATORIES TO LICENSEE'.
, SP C2 28. The answer to SP 2 is not responsive. No attempt is made to answer the sentence," Include where in the Restart Report this particular pathway is eliminated or repaired."
Ratherthan go thru the objection route , the expanded SP2 is, refiled as SP 28.
A. State which materials , filters, and items did not worR as well as expected in the vent header and filters.
B. State the page number and the paragraph number in the A Restart Report where this problem is investigated.
C. State the page number in the Restart Report wheref '
remedial action is described to eliminate each particular problem observed at TMI#2 from TMI#1 in the vent header
~
and the filters.
The answer to SP 28 requires that page numbers be f cited to be responsive.
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SP 29. The Attachments for SP 5 and SP 1$ are grossly inadequate.
Intervenor L ewis sincerely hopes that these are not the size for lettering used on drawings distributed on site.
The letters ate so small as to be completely illegible.
Resubmit working drawings as specified in SP 5 and SP 21 21 12 which meet the following guidelines:
Lettering shall be of such a size that the smallest letter la easily read,by a person with unaided 20-20 vision.
Do not send a schematin as ymaxxx yamur your entire attachment. Submit a working drawing which gives details such as ductwork , assemblies, materials and instructions to workers.
SP 30. Where did the data in SP 11 attachment A originate?
SP 31. Intervenor Lewis cannot find index to drawingpin Reptart Report. It may have been mislaid. Instruct Gilbert Associates to send another index of drawings in restart report to 6504 Bradford Ter. Ph61a. Pa19149 .
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