ML20196D392
| ML20196D392 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/31/1988 |
| From: | Skolnick F SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5585 OLA, NUDOCS 8802170099 | |
| Download: ML20196D392 (25) | |
Text
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00CNETED January 31,1988lSNRC UNITED STATES OF AMERICA NUCLEAR REGULAT0tW CatilSSION FEB 11 P6 56 BEFORE THE ATU41C SAWIY AND LICENSING BOARD gr:rce - :: q., ,
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In the Matter of ) !" C - :
GPU Nuclear Corporation ) Docket No. 50-320-01A Three Mile Island Nuclear Station, ) (Disposal of Accident Unit 2 ) Generated Water)
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SVA/IMIA'S IRIERROGATDRIES AND REQUEST FOR PRODUCTION OF DOCUMFETS TO NUCLEAR REGULATDRY C0t44ISSION Pursuant to 10 C.F.R. SS 2.740b and 2.741 and the Atcmic Safety and Licensing Board's " Maiorandum and Order ( Memorializing Special Prehearing Conference; Ruling on Contentions Scheduling )" of January 5th 1988, SVA/IMIA hereby requests that the Nuclear Regulatory Ccrrission Staff (NRC) answer in writing and under oath or affirmation, each of the following interrogatories separately and fully, and produce and permit inspection and copying of the original or best copy of all doctrnents identified in the responses to interrogatories belew Under the Ccmnission's Rules of Practice, responses to these interrogatories mst be served within 14 daysafter service of the interrogatories.
These interrogatories are intended to be continuing in nature, and the answers should prcmptly be supplemented or amerded as appropriate, pursuant to 10 C.F.R.
S 2.740 (e), should NRC or any individual acting on their behalf obtain any new or di.ffering information responsive to these interrogatories.
The request for production of doctanents is also contiming in nature and NRC aust produce innediately any additional doctments they, or any individual I
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acting on their behalf, obtain which are responsive to the request, in accordance with the pro' visions of 10 C.F.R. S 2.740 (e).
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.1. Answer the following questions for sample (s) taken from the various locations of the accident generated water (AGW),
a) State the date when sanples were drawn b) Who drew the sanples?
c) State the rethod of procurement of the sanples d) Upon what basis was it determined by the staff that the sanple(s) was representative of the tank fra which it was drawn?
e) How was the sample prepared for analysis?
f) Who undertook the analysis of the sanple(s)?
g) State the findings for all radionuclides expected in the water and indicate the lower level of detectability.
h) State the findings for all non-radioactive substances.
- 2. Concerning the "Final Results on Processed Water Testing" (letter dated January 11, 1988, Hermrandun for W.D. Travers frm D.J. Collins) answer the following:
a) State the method by which the sample was obtained from the WST 2.
b) Is this sample assuned to be representative of the total contents of the WSI 27 If "yes" answer the following:
- 1) State the basis for this assunption.
c) Is this sample assuned to be representative of the 2.3 million gallons of AGW?
If "yes" answer the following:
i) State the basis for this assunption and provide docunentation.
d) What were the findings for all radiormeludes expected to be present in the water?
e) State the findings for all non-radioactive substances.
(1)
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- 3. State the results of analysis of samples of water taken frm the reactor core and reactor tuilding basement during the period when the reactor is being defueled and the water has contained its highest concentration of:
a) boron b) hydrogen peroxide. Indicate :
a) results of smple analysis for both radioactive and non-radioactive substances for before and after Epicor II/SDS processing.
b) method of procureent of sample.
c) who procured the sample?
4 State the. basis does the staff determine that the concentration for the isotopes - Actinim 227: Americim - 241 & 242 Californium - 249 - 250, &
252; Curium 242, - 243,- 244, -245 and -246; Neptunim - 237, protractunium
-231; Plutonium 238, -237 and-239 and -242; Thorim 228 and -230 and Uranium- 232, does not exceed 1% of the total radioactivity in the AGW?
- 5. Provide d:cumentation and water sample analysis to indicate that all the AW will be processed by Epicor/SDS to provide the results indicated by GPU Nuclear listed in Table 2.2, EIS 6/87. Doc mentation should provide for results of full range of radionuclides expected to be present in the AGW.
a) does the staff expect this same reoval effectiveness for that water presently in the reactor core and elsewhere where the boron concentration is higher?
State the basis for this expectation.
b) at any time has the NRC found evidence that the Epicor I/SDS systes were not operating as efficiently as originally (1979) believed?
If "yes" state:
i) when?
ii) state the findings and subsequent water analysis, iii) what steps were taken to achieve the efficiency expected?
- 6. State the basis for the determination that : !
'%e environmental inpact fra radionuclides other than the principal ones was determined te be insignificant ( i.e. less than 1%) relative to the principal redionuclides". (EIS Final. 6/87 P 2-4)
(2)
- 7. Did the NRC undertake its own analysis of the microorganisms present in the water to determine:
a) any pathogen problems?
b) the presence of those materials which would result frcxn virus organisms?
c) Whether or not there might be any adverse effeet of releasing these micro-organisms into the environnent by any of the disposal options?
If the answer is "yes" state:
- 1) Kinds of test (s) undertaken
- 11) how the sample was procured iii) the results of these tests.
If the answer is "no", then answer:
iv) Is the NRC relying on past experienceor knowledge in dealing with these micrc-organisms? Indicate what this past experience or knowledge is to enable the NRC to make decisions about these microorganisms, d) State the basis for your claim that boiling is expected to kill off any remaining microorganisms, e) State the basis for your claim that the :tieroorganisms would remain in the evaporator bottoms and be solidified.
f) Does the hydrogen peroxide added to the water " kill " or " sterilize " the microorganisms?
g) Indicate how " killing " or " sterilizing " the microorganisms would prevent colum plugging of the SDS/Epicor systems. Provide the documntation for this assumtion. ,
- 8. What is the Maxian Permissible Concentration (MPC) in Air Above background for:
a) restricted areas?
b) unrestricted areas?
for all those radionaclides determined to exist in the water.
- 1) nam the radiorwlides which exceed the MPC for releases into the air and wac.or fort a) restricted areas b) un.'astricted areas ,
(3)
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- 9. In determining the dose / risk fr a the release of tritim into the air by evaporation:
a) was the dose assmed to be fra tritim oxide? or b) was the dose assmed to be fra tritim gas?
State the basis for this asseption.
- 10. In EIS 6/87 P. 7.5, $7.1.11 the staff states, "Although it is possible to calculate the concentration of each particular radioruclide that will result in an assmed 4-mrem dose, it could be misleading because the dose frcxn all radioruelides are mixed."
State:
a) khy it is misleading?
b) When all radioruelides expected in the AGW are included, what will be the resulting dose in mrem of disposal of the water by any option?
c) when considering the risk of exposure to radiation frce any of the disposal options, did the NRC consider the additional exposure and other adverse health implications frcxn:
i) other sources of contaminants which might adversely affeet the population within a 50 mile radius of IMI?
If "yes" state the sources considered.
ii) the adverse impact of post defueling mnitored storage?
iii) operations at Unit I?
- 11. Did the NRC consider m re recent references (than the 1963 report) for data on boron as reccomended by EPA? [EIS 6/87, letter 28 P. A53).
If "yes":
State what new information the NRC considered.
If "no":
State the basis for rejecting the EPA's reccumendation.
- 12. State the highest concentration values for all the radioruelides expected to be in the influent to the evaporator at any particular time? Provide document.ation to support this detemination.
a) what form will each of the radiomelides take (e.g. solid, gas,) dissolved in water?
(4)
- 13. Since the initial estimate of the inventory of the critiun and other radioisotopes was made and utilized in the original EIS, has the NRC received additional and/or different estimates for the amount of radio-ruclides which might be present in the water? J If "yes":
a) state any additional estimates of the inventory which were received, and b) frcrn what agency or body were the estimates of the inventory received?
If "no":
a) explain the basis for reliance on the original estimate.
1 '. . Did the NRC consider the effects which the estimated tanperature of the core at the time of the accident might have on the contents of the water?
If "yes":
a) state s at these effects were and the basis for any assunptions.
- 15. Name those chanicals or other solutions permitted by the NRC to be used by GPU tbelear for any aspect of the clean-up.
a) Was an analysis undertaken of the effect of these additions on the Epicor II, SDS, Evaporator, or other methods of disposal, or the holding tanks of the AGW?
b) Wat were the results of any analysis undertaken?
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- 16. Name all those aspects of the clean-up which will require use of the water until Unit II is placed in Post-Defueling monitored storage.
- 17. khat chanicals or other solutions are expected to be used to ecxuplete clean-up of Unit II to the point where it will be placed in post- Defueling monitored storage?
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- 18. Even though the chanicals picked up by the water in the reactor hiilding do not beccme radioactive, did the NRC analyze the effect of these chanicals on the population, upon release into the envirement?
If "yes", state :
a) the quantities and names of chanicals considered b) the results of any studies c) the basis for any conclusions (5)
I If "no": State the basis for the determination that there was no need to analyze the inpact fra non-radioactive substances.
- 19. St, ate the basis for the claim, that these elements are reoved by separation, filtration, and ion exchange processes. Indicate how the elements are detected and measured. Indicate how nuch of these elements reain. (EIS 6/87 P. 7.7 5 7.5.2)
- 20. State the name and amcunt of each chemical which has been detemined to vaporize in the evaporation option and state the basis for this determination, a) state the name or amount of each choical which would not be expected to vaporize . State the basis for this assmption. [EIS 6/87 P. 7.7 5 7.2.5 Line 32).
- 21. EIS 6/87 7.15 7.31.11 State:
a) where evaporation in an open cycle has been practised in the ruclear industry other than at Maxey Flats b) frce where did the water evaporated at Maxey Flats originate?
c) for how many years was this syste f.n operation before being closed?
- 22. EIS P 3.6 3.1.1.2 State:
a) the maxinum expected evaporation rate in gallons per minute b) the basis for the assunption that " 0.1% or less of the total particulate are toutinely achieved". State the amuunt ot total particulate in each location.
c) whether.or not all non-tritiun material'was considered when detemining the release rate.
- 23. State the basis for the assmption that the treatment to remove the micro-organisims and suspended solids are not expected to change the predictions of the envirormental inpact associated with the various disposal options.
a) what is this treatment assuned to be?
b) has the Licensee applied for permission to use any particular treatment?
(6)
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2t. . Wat is the radionuclide concentration in the evaporator bottczns for all those radionuclides expected to be present in the water?
- 25. Was the dose to the maximally exposed individual frcxn retention on-site of evaporator bottczns calculated taking account of all radionuclides present?
- 26. Is there expected to be a sediment ranaining at the bottcm of the holding tanks of the AGW ?
If "yes":
a) what would this sediment contain and b) does any expected sediment beccrne a part of the influent to the evaporator?
State the basis for these determinations.
- 27. Are there any atmospheric conditions wtiich would affect the need to alter the feed rate to the evaporator?
If "yes":
a) what are those conditions?
b) in what way(s) would it affect the feed rate?
- 25. Will the operators of the evaporator be subjected to NRC regulations and supervision?
- 29. How often will the NRC inspect the evaporator operation?
- 30. Will the NRC undertake its own periodic analysis of the evaporator influent?
If "yes":
State:
a) how often b) what is the threshold of radioactive contanination in the water above which operation of the evaporator will be made to cease?
- 31. Has the NRC considered the corrosive potential which the addition of the chlorine to the water would have on all parts of:
(7)
a) Epicor II b) SDS c) evaporator If "yes":
i) were tests undertaken? If "yes", explain the tests and the results.
If "no":
i) explain the basis for the asstcption that no tests were needed
- 11) identify past experiences and/or tests performed by the NRC on the use of moisture separators and vapor superheaters which would be used on the evaporator to insure tnat liquid droplets and dissolved canponents are not discharged with the vapor.
- 32. Will the evaporator be dismantled following disposal of the AGW and the resulting mass taken to a 1cu level waste site?
- 33. Did the staff consider the additional dose to the workers fran punp failure, hose failures, and maintenance during evaporator use?
If "no":
State reasons for not considering dose If "yes":
khat wid be the dose?
34 Explain the basis and provide information for "releases of 0.1% or less of total particulate are routinely achieved". [EIS 6/87 P3.6)
Does this refer to evaporators in an open cycle?
- 35. Upon what basis does the staff acstre that "there may be biological mechanisms that can repair damage caused by radiation at low doses and/or dose rates". (EIS 6/87 P 5.4, 5.22
- 36. Was the possible restart of UnitII a consideration in determining whether or not the AGW should be disposo;?
(8)
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- 37. If the water was to be stored in tanks on site would either the voltne or curie content or range of radionuclides present in the water preclude resunption of operations of Unit II?
- 38. When did the NRC last inspect those tanks holding the accident generated water for corrosion?
a) did any of the tanks exhbit signs of corrosion? If so; i) which ones?
ii) what is their life expectancy?
- 39. Is there an alternative to venting the tanks to the atnesphere should the water remain stored in these tanks?
- 40. Has radioactive liquid waste been stored at any site regulated by the NRC or DOE?
If "yes", state:
a) the voltrae and contents of water stored b) where was the site?
c) how long was it stored in tanks?
d) d u: were the consequences if any?
e) did the tanks remain intact?
- 41. In determining whether or not to dispose of this water, has the NRC relied on any past experiences of any utility or foreign goverrment?
If "yes", state:
a) where was this water located?
b) what was the experience upon which the NRC relied?
c) is there evidence available showing adverse affects ofdisposing of such water?
If "yes", what is the evidence?
(9)
r GENERAL INTERROGATORIES FOR 11E NRC STAFF
- 1. State the rare,present or last known address,present or last kzum ecployer, professional and educational qualifications for the following persons:
a) Those persons who foraulated the EIS, Supplement #2.
b) Those persons who attended any meeting (s) with the Licensee "to discuss items of information provided ,to seek new information from the Licensee that might be needed for an adequate assessment," (EIS Nureg 0683,Supplementf2 Final Report, June 1987,P.ix).
Respectfully Sutaitted, j 's a .* '
D^%) Y '.DA .
Frances Skolnick
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- 1. Any notes, tapes, transcripts, or other doctnents ensuing fra the meeting (s) between NRC and GPU thelear concerning disposal of the water (EIS Pix, 6/87). l
- 2. Doctments pertaining to analysis of the water following processing by I
Epicor II/SDS.
- 3. Documents pertaining to analysis of water sanples drawn frm the reactor core and reactor building basanent prior to processing by Epicor~ II/SDS.
4 Documents pertaining to any analysis or tests related to the following:
a) microorganisms in the Accident Generated Water (AGW) b) chenicals in the AGV
- 5. Documents pertaining to the more recent (other than 1979) estimates of the core inventory.
- 6. Doctments pertaining to the environmental impact caused by boron.
- 7. Doctments to provide evidence that non-radioactive substan:es will be ratoved by separation, filtration and co-exchange processes.
l l 8. Doceents showing that open cycle evaporation is practised in the j tuelear industry.
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- 9. Documents pertaining to the results of any tests showing the effect of corrosive agents ont a) Epicor II b) SDS c) Evaporator
- 10. Doc eents. to support the assumption that there are biological mechanis:ns
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- i which can repair damage caused by radiation at low doses and/or dose rates.
- 11. Documents related to the ef fectiveness of moisture separators and vapor superheaters on evaporators operating in an open cycle mode.
- 12. Docunents to provide evidence of the expected decontamination factor of the evaporator operating in an open cycle.
- 13. Documents to provide evidence that releases of .1% or less of the total particulate will be achieved by the evaporation in an open cycle.
- 14. Docments danonstratir.g the amount and canponents of:
a) total gases b) total particulate c) total dissolved radionuclides in the AGW F
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, USHR M KD $ RRES,P0fDE g 2 FEB 11 P7 69 DEFINITIONS AND INSIRUCTIWS gf 8MC1.a lCE ; $! cr m.,, ,
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'Ibe following definitions are applicable to each interrogatory and are imorporated by reference in each interrogatory. 'Ihe interrogatories aust be read in the light of these definitions and your answers aust be responsive to the interrogatories as so defined.
- 1. "Doctrnent": 'Ihe term docment means any written, recorded,' printed, typed or other graphic matter of any kind or nature, however produced or re-produced, whether sent or received or neither, including drafts or copies bearing meaning, notations or marks not found on or in the original, and includes but is not limited to:
(a) all letters or other forms of correspondence or comunication, including envelopes, notes, telegrams, cables, telex nessages, messages (including reports, notes, notations and memoranda or or relating to telephone conversations or conferences.)
(b) a11' memoranda, reports, test results, notes, transcripts, tabulations, studies, lists, canparisons, charts, graphs, smmaries, extracts, statist-ical records, ccanpilations.
(c) all desk calendars, appointment books, diaries (d) all books, articles, booklets, bulletins, notices, instructicos, maruals (e) all photographs, microfilms, tapes or other records, punch cards, magnetic tapes, discs, data cells, print-outs ad other data ccrnpilations frcrn which information can be obtained.
(1)
DSd3
- 2. "Camunication": The tem "Camunication" means not only oral comunication but also any "documento" (as such term is defined in paragraph 1. above),
whether or not such document or the information contained therein was transmitted by its to any other person.
- 3. "Identify", "Identity", or " Identification":
(A) When used in reference to a natural person, the tems "identify",
"identity", or "identification" seek the fo11owin6 nformation:
i (i) full names (ii) present or last known business address (iii) present or last known business affiliations and (iv) present or last known business position (including job title and a description of job functions, duties and I responsibilities)
(B) When used with reference to any entity other than a natural person, the terms "identity, "identify", or"identification" require:
(i) its full names (ii) the address of its principle place of business (iii) the jurisdiction under the laws of which it has been organised or incorporated and the date of such organisatico or incorporation, if known:
(iv) the identity of all individuals who acted or who authorised another to act on its behalf in connection with the matters ,
referred to (v) in the case of a corporation, the names of its directors and
! prirriple officers: and ;
t (2)
(vi) in the case of an entity other than a corporation, the identities of its partners or principles or all individuals who act on its behalf in connection with metters referred to, (C) When used in reference to a doement, the terms "identify",
"identity", or "identification" mean to provide the following information:
(1) the nature of the docunent (s., letter, ccotract, memorandm) and any other information (i.e., its title, index or file nurnber) which would facilitate in the identifie-ation thereof (ii) its date of preparations (iii) its present location and identity (as defined in paragraph 3 (A) hereof) of its present custodian or, if its present location and custodian are not kruwn, a description of its last known dispositicn:
(iv) its subject matter and substance or, in lieu thereof, annex a legible copy of the doeurnent to the answers of those interrogatories:
(v) the identity (as defined in paragraph 3 (A) hereof) of each person who performed any significant fmetion or had any role in connection therewith (i.e. , author, contributor f
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of information, recipient, etc.) or who has any knowledges i
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(vi) if the document has been destroyed or is otherwise no longer l ,
l in existerce or cannot be found, the reason, if known, why ,
such document no longer exists, the identity (as defined in 1
(3)
paragraph 3 (A) hereof) of the person responsible for the document no longer being in existence and of its last known custodian.
(vii) the portion or portions of the document (whether section(s),
chapter (s), or page(s) upon which GPU relies (D) Wen used in connection with an oral ccumunication, the terms "identify", "identity", or "identification" mean to provide the following information:
(i) its general nature (i.e._, ecoference, telephonic ecrmunication, etc.):
(ii) the time and place of its occurence; (iii) its subject matter and substances (iv) the identity (as defined in paragraph 3 (A) hereof) of each person who performed any function or had any role in connection therewith or who had my knculedge thereof and (v) the identity (as defined in paragraph 3 (B) hereof) of each document which refers thereto or which was used, referred to or prepared in the course or as a result thereof.
(E) When used in econection with a stati:te, regulation, or any other legal requirment, the terms "identify", "identity", or "identifi-cation" mean to provide the ecznplete legal citation, by section and subsection, or where ro such citation exists, any information necessary to facilitate its location.
(4)
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- 4. "Nscribe" or "Description":
(A) When used with respect te any act, action, accounting, activity, audit, practice, process, occurrence, occasion, course of conduct, happening, negotiation, relationship, scheme, ccumunication, conference, discussion, development, service, transaction, instance, in:ident, or event, the terms "describe" or "description" mean to provide the following information:
(i) its general natures (ii) tha time and place thereof:
(iii) a chronological account setting forth each element consisted of and what transpired as part thereof (iv) the identity (as defined in paragraph 3 (A) hereof) of each person who performed any furetion or had any role in connection therewith (i.e. , speaker, participant, contribu-tor of information, witness, ste.) or who has any knowledge thereof:
(v) the identity (as defined in paragraph 3 (B) hereof) of each doctment which refers thereto or which was used, referred to or prepared in the course or as a result thereof and (vi) the identity (as defined in paragraph 3 (C) hereof) of each oral ccumunication which was a part thereof or or referred thereto.
(B) When used in comection with any test data the terms "describe" or "description" mean to provide the following informatico (5)
e (i) all calculations, emputer printouts and any other docu-mentation used to obtain stated test results, including sequence of testing (ii) an explanation of its meaning (including the nature, ;
source and meaning of each ewgsit part thereof):
(iii) an explanation of the manner in which it was derived (iv) the identity (as defined i.n paragraph 3 (A) hereof) of each person who performed any function with respect thereto (v) the identity of each doement (as defined in paragraph 3 (B) hereof) which refers thereto or dich was used, referred referred to or prepared in the course or as a result thereof; and (vi) the identity (as defined in paragraph 3 (C) hereof) of each oral camunication which occurred in the course of the preparation thereof or which referred thereto.
- 5. "Factual Basis": The term "factual basis" means (A.) set forth each itan of information upon which the allegation, contention, claim or assertion to which it pertains is based, and (B) with respect to each such item of infouration identify each person having knowledge thereof and identify and describe (as defined in paragraphs 3 and 4 hereof) each source thereof, including but not limited to each doceent oral comunication, act, action, activity, accounting, negotiation, practice, proecss, occurrence, occasion, course of conduct, happenin6, relationship, scheme, conference, discussion, development, service, instance, L
L (6)
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c ircident, event, calculation and ccinputation upon which you rely with respect thereto.
- 6. "Reistes to": The term "relates to" or "relatirg, to" Wn used in connection with any act, action, activity, accotating, practice, process, occurrence, occasion, course of conict, contractual provision or docunent, happening, relationship, scheme, ccafererce, discussion, development, service, instance, ircident, event, etc., means used or occuring or referred to in the preparation thereof, or in the course thereof, or as a consequence thereof, or referring thereto.
- 7. "Person": The term "person" means all natural persons, corporations, partnerships or other business associations, public authorities, cunicipal corporations, state goverunents, local governments, all govemnental bodies, and any other legal entities..
Answer by reference to Docunents: Identify each and every docuner.t 8.
which you claim supports each fact set forth in your answers to the Interrogatories. With respect to each answer, identify (as defined in paragraph 3 (C) hereof) the specific docunent, docunents, or portions thereof identified by page and paragraph nLeber within the page, containing the requested information, or attach a copy to the answer hereto.
- 9. For each interrogatory answer, identify each person who participated in the preparation of the answer, and who provided information to you upon which you relied in preparing answer, and precisely what i
information was provided by each such person.
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- 10. "Licensee": "Licensee" includes Metropolitan Edtsen Canpany and GPU tbelear Corporation, and all present and fomer officers, enployees, agents, and all other persons, engineering or censulting firms or carpanies acting or purporting to act on behalf of Het Ed. GPU thelear, and/or any kind and all parent and predecessor entities, i
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- 11. "You" means any neber or m=hars of the 10C staff, its envioyees, agents, and all other persons acting or purporting to act on its behalf.
- 12. "State the basis" includes the factual, legal and other bases for the relevant assertion, and includes the terms "factual basis," "identify,"
and "describe" as defined herein.
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4 10."You/GPu" 'Nou dr GPU" ' includes Metropolitan Edisco Cagany and GPU lbelear Corporation, and all present and former officers, agloyees, agents, and all other persons, engineering or consulting !Lrms or ecapanies acting or purporting to act on be41f of Het Ed, GPU lbelear, and/or any kind and all parent and WA sssor entities.
- 11. "NRC" ' means any ownber or members of the NRC staff, its anployees, agents, and all other persons acting or purporting to act on its behalf.
- 12. "State the basis _" includes the factual, legal and other bases for the relevant assertion, and includes the terms "factual basis," "identify,"
and "describe" as defined herein.
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k t-t' 00C80iEC' c USNP.C r2CATtoccRRCtPOJW9iC3 fee @6hlN N OFFICE Or iiJe I A"'
00CKCilHG A 1CiWICl-BRANCH IMITED SIATES OF AMERICA NUC12AR REGUIATORY (XM(ISSION EFORE THE ATQi1C SAFrrY AND LICENSING BOARD
, In the Matter of ) Docket No. 50-320-01A
)
GPU Nuclear Corporatim ) Disposal of Accident-Three Mile Island Nuclear Station, )
)
Generated Water
)
Unit 2 ) i CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "SVA/IMIA'S Interrogatories and Request for Production of Documents to NRC rad to GPU ikselear were served this 7th day of February, 1988 by Way Messenger Service upon the NRC and GPU, and by first class postage prepaid mail on Febnsary 8th, to the rarainder of the service list.
f t O
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'(70LtGA.D Frances Skolnick t
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( .- l SERVICE LIST
,' I Sheldon J. Wolfe, Chairman John R. McKinstry, Etg.
Administrative Judge Assistant Counsel Atomic Safety and Licensing Commonwealth of Penn.
Board Panet S05 Executive House U.S. Nuclear Regulatory Commission P,0. Box 2357 I
Washington, D.C . 20555 Harrisburg, Pa. 17120 Glenn O. Bright Thomas A.;B:..ter, Esq.
Administrative Judge Shaw, Pittman, Potts c.
Atomic Safety and Licensing Trcubridge Board Panel 2300 N Strost, N.W.
U.S. Nuclear Regulatory Ccemission Washington,-DC 200M Washington, D.C. 20111 Dr. Oscar H. Paris Stephen H. Lewis, Esq.
Administeative Judge Office of the General Atomic Safety and Licensing Counsel Board Panel U.S. Nucl e ar Regulatory U.S. Nucl ear Regul atory Commission Commission Washington, D.C. 20555 Washington, DC 20555 Dr. William D. Travers Ms. Vera Stuchinski Dir. Three Male I s l t.n d Three Mils Island alert Cl eanup Proj ec t Directore 315 Peffer Street P.O. Box 311 Harrisburg, Pa. 17102 Middletown, Pa. 17057 .
Docketing & Services Branch Secretary of the Ccmnission U.S.N.R.C.
Washington,DC 20555.
MCM w Frances Skolnick
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