ML19247B231

Responds to Util Interrogatories.Certificate of Svc Encl

ML19247B231
Person / Time
Site:	Fermi
Issue date:	07/06/1979
From:	Petzel D CITIZENS FOR ENERGY & EMPLOYMENT
To:
References
NUDOCS 7908080210
Download: ML19247B231 (4)

Text

. .. $N gsW .

Iu'I,\TED coauuMPONDmOB h 9 4

0!

yd'.y$ W As ' *b g -

UNITED S RATES OF AMERICA Q gd?[# .~ '

NUCLEAR REGULATORY CO.'etISSION

\g'

., p,8 Y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Q' '/,

. 5 [Y.V % 8

% W In the matter of )

)

THE DETROIT EDISCN COMPANY ) Docket No. 50-341 (Enrico Fermi Atomic Power ) (Operating Licenre)

Plant, Unit 2) )

CEE'S RESPONSES TO INTERROGATORIES h comes the Citizens for Employment and Energy (CEE), by David Pet:el, one o f i t s membe rs , 4ho having been duly sworn la response to the interrogatories served upon CEE b:. the Applicant i." the above matter, makes the following an-swers and responses

1. Ihere is some uncertainty as to who will be testifying on behalf of CEE.

As soon as a detemination is made in regards to the specific individual or indi-viduals who will testify on CEE's behalf, the specific information requested in this interrogatory will be furnished the Applicant.

2.

CEE is prepared to release the information requested to the Nuclear Regula-to y Commission, but is not ready at this time to release such information to the Detroit Edison Company, or any employee, servant or attorney representing Appli can t , being fearful of possible direct repercussions and possible adverse ef fects on the employment of such individual (s) .

3.

In response to (a), CEE will be better able to -espond after reviewing the materials submitted by Applicant in response to CEE's interrogatories. GE is attempting to obtain further information en the reinspection contention, and will provide a more detailed response. as soon as such information becomes avai.-

able to it.

4 CEE eill be better able to respond to (a) after reviewing Applicant's responses to our interrogatories. In regards to (b), CEE understands that destruction of records through Imruing may have taken place shortly after construction work was halted in 1974 We are attempting to obtain further specifics and will provide such information when it becomes availabic to us.

5. 10 C.F.R. Part 2 0 an d 10 C . F . R . Part 50 set general criteria for radiation ncnitoring systems. CEE conten ts that the lack of provisicn for continuous moni-toring that enn a read rematcl:. does not ecnform with the general criteria. CEE needs to review Applicant's ' te emergency plan to respond to (b) .

3. CEE does not current 1; ha"a in its posession a copy of " Standard Review Plan" re fe rred to by Applicant. he are making efforts to obtain this document and will respond to this interrogatory after we have an opportunity to fully study the Review Plan and Applicant's response to ir. ..

f )() !NO 79o8080 N

o a 7 According to information orovided by the Arny Corps of Engineers, the maximum height above sea leave since 1973 appears to be about 375 feet, occurring in June ,

1973.

S. These responses have been prepared by David Petzel, member of CEB and Kizi irthur Siegfried, attorney for CEE.

1 .

? /

r  !. .7 / ..

David Petzel, Member, CEE Sub ieribed and sworn to before e, yh i.s 4- day of 7 .._4 ,'i 'i t, 'l C(

I

, O .'% . ~

p '

_? NN'\s,i ce F. - \ \. U%'

Tha .:._

-KENNETH J. TRUSSELL Netary Public, Oakland County, Mich.

My Cormnission Expires Cec.12,19C

/

l a-

. ,3 t /

, , *2 s ::

/

Y,Qr"g?, :,j iN[(

~

D ca o,q%  ? #2 cp

, V

1. 4K

. .)

UNITED STATE 3 OF AMERICA n -o ECLEAR RECULATORY CCMMISSION m, .

y%..'_%sS"-

1. . ^ [,

'YM.UE THE ATnMTC St7ETV JD I,TCENSTNG BC ARD

\[n'AA  :

9h'#"/ 9 '

s' ry n a n the Mat ter o f )

THE DETRCIT EDI30h CUMPANY ) Cocket No. 50-341 (Enrico Fermi Atcmic Power ) (Operating License)

Plant, Unit 2) )

CERTIFICATE OF SERVICE I hereby certify that I have this 6th day of July, 1979 served the foregoing document entitled "CEE's Responses to Interrogatories" by mailing copies thereof, first class mail, postage prepaid and properly addressed, or by personal delivery, as so indicated, to the following persons:

Charles Bechhoefer Esc. .

Chairman, Atomic Safety and Dr. David R. Schink Licencing Board gepartment of Oceanogrnphy U.J. Nuclear Regulatory texas A&M University Commis ion College Station, Texas 778E, llashingt;n, D.C. 20555 Richard Black, Esq.

% .,_,., - q, .

,,_ C f fice o f the Executive to ic 5$ heb* 'cb~ Li $c$ sing Lgg 1 Director

~u-u m, . U. c. ..uclear Regulatory J..;. Juclear Regulatorv Co= mission Commission

.# shington, D. C. 20555

1. ashington, D.C. 20555 ;4r. Delbert J ..o n f fman Chairman, Atomic Safety and uperdsor, Frenchtown Licensing Aeneal Board Pane, Township U.S. Nuclear liegulatory trenchtown Townsnip Hall Commission 2665 Vivian Roac

?lashingto n , D.C. M nr e, Michigan 48161 20555

,c;,

jj k t'. Jl

s Monroe Ccunty Library System Secretary Reference Departmenc U.S. Nuclear Regulatory 37COdouth Cuctor Road Commicsion

a nro e , Michigan LJ161 Washington, D. C. 20555 Attn: Docketing and Service Ec.rry H. Vcigt Section Leboeuf, Lamb, Leity & MacRae lj33New Hampshire Ave, N.W.

ilashingten, D. C. 20036 Peter A. Marquardt, Esq. ,

The Detroit Edison Company -

2000 Second Avenue David Petzel Detroic, Michigan Member CEE O

/

') '

.O -

'1 I

's '

.