ML19323H757
| 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) | |
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ypED CORRESPONDN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Metter of )
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METROPOLITAN EDISON COMPANY ) g
) Docket No. 50-289 [*-
(Restart)
(Three Mile Island Nuclear ) DCOG* $
Station, Unit No.1) k W
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2 p,\Y 13 ESO > )r
{ pc3 ct es 9mtm4t'r i pgg-c, & kr.ic .
' 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:
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- 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
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- 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.
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By: '
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h Theodore A. Adler
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P . O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 Dated: May 13,1980 i
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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 CW I;\
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Raleigh, NC 27612 ~
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c;. MAY 131920 >
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
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/ Theodore A. Adler Dated: May 13,1980 l
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