ML19309E415

Response to ASLB 800325 Memorandum & Order,Stating Objective of Intervenor Discovery & Deposition Program.Prospected Info Will Spotlight Licensee Internal Weakness.Participation in Future Depositions Uncertain.Certificate of Svc Encl

ML19309E415
Person / Time
Site:	Three Mile Island
Issue date:	04/02/1980
From:	Adler T THREE MILE ISLAND ALERT
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004220011
Download: ML19309E415 (3)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) l METROPOLITAN EDISON COMPAlf ) Docket No. 50-289 (Restart) 9 D

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(Three Mile Island Nuclear ) & 4 Station, Unit No.1) ) DOCKETED '

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RESPONSE OF TMIA, INC. TO BOARD I i MEMORANDUM AND ORDER DATED Branc.g MARCH 25,1980 9 d i

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In response to this Board's Order of March 25, 1980, TMIA, Inc., submits l l

I the following:

The primary objective of TMIA's discovery and deposition program, as it relates to management, is to continue some of the work the Kemeny staff had begun but had neither the time nor resources to continue, and to develop those areas which had not been investigated at all. These latter areas include: (1) deferred and temporary maintenance on safety-related components, (2) lack of objective and uniform priorities for maintenance work orders, (3) sufficiency of competent manpower in all areas, (4) the competency of contractors and suppliers, (5) quality control, and (6) health physics.

1 See Report of the Office of Chief Counsel on The Role of the Managing Utility and Its Suppliers, pp. 2 (Paragraphs 2-4) ,198.

8 0042 2 o Oil 8% ,

The information that would be developed, TMIA believes, will spotlight ,

the internal weaknessas of Licensee that were a contributing factor to the TMI-2 accident and will demonstrate that these weaknesses continue today. Apart from the depositions scheduled, however, is the need to track down former employees who, TMIA believes, have information relevant to the operations at TMI-1. The l i

lack of funding has made it virtually impossible to employ private investigators to track these people down. Furthermore, former employees, particularly Terry Mackey, who headed qurlirl control and is now in Brazil working for NUS, are beyond the reach of this Board unless funds are made available.

The Board also asks whether counsel for TMIA will participate in deposi- l tions if they are underwritten by the staff. Presently, counsel for TMIA has spent ]

in excess of 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on this proceeding and the related Public Utility Commission i

proceeding without payment. Ultimately, counsel hopes that it will be paid. As j to whether counsel can continue to participate on an unlimited basis as it has done l in the past is uncertain. Nevertheless, before any schedule of future depositions was agreed upon, TMIA counsel's participation would be clear one way or the other.

R'espectfully submitted, WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.

By: 2 Theodore A. Adler

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Dated: April 2,1980 0

CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document, Response Of TMIA, Inc., To Board Memorandum And Order Dated March 25,1980, to be placed in the United States mail, first-class, postage prepaid, addressed to the persons listed below:

Ivan W. Smith, Esquire 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 4 DCCg $

Dr. Linda W. Little 5000 Hermitage Drive %Vec -

Raleigh, NC 27612 w M8 g d George F. Trowbridge, Esquire e ng 2 8'3'a Shaw, Pittman, Potts & Trowbridge DJ 1800 M Street, N.W.

Washington, DC 20006

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Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U .S . Nuclear Regulatory Commission Washington, DC 20555 Theodore A. Adler

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Dated: April 2,1980 i