ML19257C132

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Forwards Response to TMI Alert,Inc First Set of Interrogatories in Restart Proceeding.Documents Re State of PA Emergency Plan Were Distributed to All Participants in Nov 1979
ML19257C132
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/08/1980
From: Carter K
PENNSYLVANIA, COMMONWEALTH OF
To: Adler T
WIDOFF, REAGER, SELKOWITZ & ADLER
Shared Package
ML19257C133 List:
References
NUDOCS 8001250016
Download: ML19257C132 (1)


Text

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DEPARTMENT OF ENVIRONMENTAL RESOURCES

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Theodore A. Adler, Esquire -i' 'U Se,

[ Widoff, Reager, Selkowitz & Adler *' -' O' j Post Office Box 1547 Harrisburg, Pennsylvania 17105

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Re: Three Mile Island Unit 1 tac Dacket tb. 50-289 (Restart)

Dear Ted:

h Enclosed is the Cormo:rmalth's response to TMIA's first set of f

interrogatories.

f In'those cases where the " interrogatories" were document requests, we have treated them as such. The documents requested have been enclosed herewith, except for the Cormorrealth's emergency plan, wMch was distributed by the Suspended Licensee to all parties in tbvenber,1979, and wMch j should therefore already be in TMIA's possession.

t 4 The Comromealth has not responded to Interrogatories tbs.17-22 h

because the Atomic Safety mi Licensing Board, in its order of Decenber 18, 1979, has tuled that the contention to which these interrogatories apply (7MIA Contention 4) is beyond the scope of this proceeding.

Counsel for the Conmarrealth has endeavored to contact all Connun-wealth agencies which might have had docuaents or informaticn wMch should be incorporated in the responses to 7MIA's interrogatories. These agencies consisted of the Office of the Governor, Office of the Lieutenant Governor, Pennsylvania F2ergency Management Agency, Department of Environmental Resources, Department of Health, and State Police. The only agency from wMch counsel has not yet completed gathering possibly relevant doctments or infonration is the State Police. It is expected that relevant State Police documents or interrogatory responses, if any, will be submitted to you within ten days.

With the above limitations, the Camomealth has provided complete responses and all the documents requested. However, we request that 7MIA make any requests through counsel to contact Cormomvalth enployees whose telephone numbers are listed in the enclosed responses.

Very truly yours, N- '

KARIN W. CARTER Assistant Attorney General 1804 269 J soonso O >6