ML19257C132
| ML19257C132 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| 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
717-787-7060 L.1;.
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ONWEALTH or PENNsg
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DEPARTMENT OF ENVIRONMENTAL RESOURCES
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January 8, 1980
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Theodore A. Adler, Esquire
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Widoff, Reager, Selkowitz & Adler O'
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Harrisburg, Pennsylvania 17105
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v 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
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