ML19257C136

First Set of Interrogatories Directed to Intervenor TMI Alert,Inc.Requests Info Re Allegation That I-133 & Kr-88 Released in Excess of Permissible Limits During TMI-2 Accident.Certificate of Svc Encl

ML19257C136
Person / Time
Site:	Three Mile Island
Issue date:	01/14/1980
From:	Trowbridge G METROPOLITAN EDISON CO.
To:	THREE MILE ISLAND ALERT
References
NUDOCS 8001250020
Download: ML19257C136 (40)

Text

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Dated: January 14, 1980

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UNITED STATES OF AMERICA s$# o e NUCLEAR REGULATORY COMMISSION f[ gF MM /'a'<9 a

' _] qp > f s xv .s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '3 h 97 # -

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In the Matter of 'r d METROPOLITAN EDISON COMPANY ) Docket No. 50-289 '

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR THREE MILE ISLAND ALERT, INC.

These interrogatories are filed pursuant to 10 C.F.R.

S2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation.

Licensee recognizes that Intervenor Three Mile Island Alert, Inc. ("TMIA") may not now be able to completely answer all interrogatories propounded below, since some areas are the subject of discovery by TMIA, although Licensee notes that it has already respondet. to two sets of TMIA interrogatories.

Licensee therefore requests that each of these interrogatories be answered within the time specified in S2.740b to the extent that responsive information is presently available to TMIA.

With respect to those interrogatories for which complete and responsive information is not now available to TMIA, Licensee requests that revised answers be provided prior to the close of the discovery period established in the Licensing Board's December 18, 1979 First Special Prehearing Conference Order.

1804 291 soosesooh

n .

Any reference to Intervenor Three Mile Island Alert, Inc.

("TMIA") shall be deemed to include all members of TMIA. When knowledge or information of TMIA is requested, such request includes knowledge or information of TMIA's members and, unless privileged, its attorneys.

The following definitions apply to each of the inter-rogatories below:

A. " Document" means all writings and records of every type including, but not limited to memoranda, tapes, correspon-dence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, logs, speeches, articles, transcripts and all other records, written, electrical, mechanical or otherwise.

B. " Identify" means:

(1) With respect to a natural person, name, present or last known home or business address, present or last known job title or position, and the dates of tenure in that position; (2) With respect to a docu.aent, the type of document (e.g., letter, record, list, memorandum, memorandum of telephone or face-to-face conversation, etc.), date of the document, title of the document, subject of the document, name of person who prepared the document, and name of person for whom the document was prepared or to whom it was delivered.

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Interrogatories on Contention No. 1 1-1 Identify all dates on which TMIA contends that, as a result of the accident at Unit 2, I-133 was released into the atmosphere "in excess of permissible limits."

a. Identify the 34 day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the 26.84 Ci measurement specified in the allegation.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation, including the 26.84 Ci measurement specified in the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the 26.84 Ci measurement specified in the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to I-133.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that 2 t ut is used in the allegation with respect to I-133.

1-2 Identify all dates on which TMIA contends that, as a result of the accident at Unit 2, Krypton-88 was released into the atmosphere "in excess of permissible limits."

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the 6.lE+4 Curies measurement specified in the allegation.

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b. Identify all documents containing any evidence or information bearing upon or relating to the allegation, including the 6.lE+4 Curies measurement specified in the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation, including the 6.lE+4 Curies measurement specified in tne allegation.

d. Define " permissible limits" as that term is used in the allegation with respect to Krypton-88.

e. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Krypton-88.

1-3 Identify all dates on which TMIA contends that, as a result of the accident at Unit 2, Xenon 133M was released into the atmosphere "in excess of permissible limits."

a. Identify the ten day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the measurement of 170,000 Curies specified in the allegation.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation, including the measurement of 170,000 Curies specified in the allegation.

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i ,

d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the measurement of 170,000 Curies specified in the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Xenon 133M.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Xenon 133M.

1-4 Identify all dates on which TMIA contends that, as a result of the accident at Unit 2, Xenon 135 was released into the atmosphere "in excess of permissible limits."

a. Identify the seven day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the measurement of 1.5 million Curies specified in the allegation.

c. Identify all documents containing any evidence or information relating to the allegation, including the measurement of 1.5 million Curies specified in the allegation,

d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the measurement of 1.5 million Curies specified in the allegation.

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e. Define " permissible limits" as that term is used in the allegation with respect to Xenon 135.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Xenon 135.

1-5 Identify all dates on which TMIA contends that, as a result of the accident at Unit 2, Xenon 135M was released into the atmosphere "in excess of permissible limits."

a. Identify the three day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the measurement of 140,000 Curies specified in the allegation.

c. Identify all documents containing any evidence or information relating to the allegation, including the measurement of 140,000 Curies specified in the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the measurement of 140,000 Curies specified in the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Xenon 13; 1.

f. Identify all NRC and other aget y regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Xenon 135M.

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i .

1-6 Identify all isotopes of Xenon, other than Xenon 133M, Xenon 135, and Xenon 135M, which TMIA contends were released into the atmosphere "in excess of permissible limits" as a result of the accident at Unit 2.

a. For each isotope listed, identify the dates on which TMIA contends that releases "in excess of permissible limits" occurred as a result of the accident at Unit 2.

b. For each isotope listed, identify the total quantity which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

c. For each isotope listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

d. For each isotope listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

e. For each isotope listed, identify all persons having any knowledge supporting or relating to the allegation.

f. Define " permissible limits" as that term is used in the allegation with respect to each of the isotopes of Xenon listed, other than Xenon 133M, Xenon 135, and Xenon 135M.

g. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to each of the isotopes of Xenon listed, other than Xenon 133M, Xenon 135, and Xenon 135M.

1804 297 1-7 Identify all dates on which TMIA contends that Ruthenium-103 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Ruthenium-103 which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Ruthenium-103.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Ruthenium-103.

1-8 Identify all dates on which TMIA contends that Ruthenium-106 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Ruthenium-106 which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

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c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Ruthenium-106.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Ruthenium-106.

1-9 Identify all dates on which TMIA contends that Tritium was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Tritium which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Tritium.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Tritium.

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1-10 Identify all dates on which TMIA contends that Bromine-82 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-82 which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Bromine-82.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-82.

1-11 Identify all dates on which TMIA contends that Bromine-83 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-83 which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

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c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limitt" as that term is used in the allegation with respect to Bromine-33.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-03.

1-12 Identify all dates on which TMIA contends that Bromine-84 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-84 which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in . e allegation with respect to Bromine-84.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-84.

i804 301 1-13 Identify all dates on which TMIA contends that Bromine-85 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-85 which TMIA contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation,

e. Define " permissible limits" as that term is used in the allegation with respect to Bromine-85.

f. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-85.

1-14 Identify all radioactive gases--other than I-133, Krypton-88, Xenon 133M, Xenon 135, Xenon 135M, isotopes of Xenon identified in response to 1-7, Ruthenium-103, Ruthenium-106, Tritium, Bromine-82, Bromine-83, Bromine-84 and Bromine-85--which TMIA contends were released into the atmosphere "in excess of permissible limits" as a result of the accident at Unit 2.

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a. For each gas listed, identify the dates on which TMIA contends that releases "in excess of permissible limits" occurred as a result of the accident at Unit 2.

b. For each gas listed, identify the total quantity which TMIA contends was released into the atmocphere as a result of the accident at Unit 2.

c. For each gas listed, set forth each and every f act and the source of each and every fact upon which the allegation is based.

d. For each gas listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

e. For each gas listed, identify all persons having any knowledge supporting or relating to the allegation.

f. Define " permissible limits" as that term is used in the allegation with respect to each gas listed.

g. Identify all NRC and other agency regulations upon which TMIA relies in defining " permissible limits" as that term is used in the allegation with respect to each of the gases listed.

1-15 Define "long term health effects" as that term is used in the allegation.

1-16 Describe in detail the "long term health effects" which TMIA contends that TMIA members will suffer as a result of the release into the atmosphere, at levels allegedly "in excess of permissible limits," of the following gases:

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a. I-133.

b. Krypton-88.

c. Xenon 133M.

d. Xenon 135.

e. Xenon 135M.

f. Each of the isotopes of Xenon identified in response to 1-6, above,

g. Ruthenium-103.

h. Ruthenium-106.

i. Tritium.

j. Bromine-82.

k. Bromine-83.

1. Bromine-84.

m. Bromine-85.

n. Each of the gases identified in response to 1-14, above.

1-17 In alleging that " radiation affects the body in a cumulative manner," does TMIA contend that the radiation associated with the normal operation of Unit 1 and the radiation associated with the Unit 2 accident will have a greater total effect (i.e., a synergistic effect) on the health of TMIA .nembers than the simple sum of the radiation associated with the normal operation of Unit 1 and the radiation associated with the Unit 2 accident? If not, set forth with precision and particularity the relationship TMIA describes in its allegation that " radiation affects the body in a cumulative manner."

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a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

1-18 Describe with precision and particularity the interrelationship which TMIA alleges among (1) the radiation associated with the normal operation of Unit 1, (2) the radiation associated with the accident at Unit 2, and (3) the

" planned and unplanned discharges of radiation" which TMIA contends will occur during the cleanup of Unit 2, including all combinations of these three sources of radiation, with respect to the health of TMIA members.

a. Are the terms " cumulative effect" and

" cumulative manner" (as that term is defined ir. response to 1-17, above) synonymous? If not, define " cumulative effect" as the term is used in the contention and distinguish it from

" cumulative manner," as that term is used in the contention,

b. As F.o each interrelationship which TMIA alleges between and among the three numbered sources of radiation identified in 1-18, set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. As to each interrelationship which TMIA alleges between and among the three numbered sources of radiation 04 305

identified in 1-18, identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. As to each interrelationship which TMIA alleges between and among the three numbered sources of radiation identified in 1-18, identify all persons having any information or knowledge supporting or relating to the allegation.

Interrogatories on Contention No. 2 2-1 Describe the nature and source of the " additional low-level radiological discharges from Unit #1" to which TMIA refers in the contention.

a. Define " low-level radiological discharge" as that term is used in the allegation.

b. Identify all NRC and other agency regulations upon which TMIA relies in defining " low-level radiological discharge" as that term is used in the allegation.

2-2 Describe in detail any and all "significant adverse ef flect ( s] on the water quality in the Susquehanna" which TMIA contends will result solely from the " low-level radiological discharges from Unit #1."

a. For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

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b. For each effect listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

2-3 Identify the "high-level discharges" (including the source of each discharge, an analysis of the discharge, and the date of discharge) which TMIA contends have been discharged in the Susquehanna "as a result of the TMI accident."

a. For each discharge listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each discharge listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. For each discharge listed, identify all persons having any information or knowledge supporting or relating to the allegation.

d. Define "high-level discharge" as that rm is used in the allegation.

e. Identify all NRC and other agency regulations upon which TMIA relies in defining "high-level discharge" as that term is used in the allegation.

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2-4 Ideatify the "high level discharges" (including the source of each discharge and an analysis of the discharge) which TMIA contenda will be discharged in the Susquehanna "as a result of the TMI accident."

a. For each discharge listed, set forth each and every fact and the source of each and every fact upon which the allegation is based,

b. For each discharge listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. For each discharge listed, identify all persons having any information or knowledge supporting or relating to the allegation.

2-5 Describe in detail any and all "significant adverse effect[s] on the water quality in the Susquehanna" which TMIA contends have resulted and will result frcm the "high level discharges" identified in response to 2-3, above.

a. For each effect listed, set forth each and eve:y fact and the source of each and every fact upon which the allegation is based.

b. For each effect listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

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2-6 Describe in detail any and all "significant adverse effect[s] on the water quality in the Susquehanna" which TMIA contends will result from the "high-level discharges" identified in response to 2-4, above.

a. For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each effect listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

2-7 Describe in detail any and all "significant adverse effect[s] on the water quality in the Susquehanna" which TMIA alleges will result from the combination of the " low-level radiological discharges from Unit #1, in addition to those high-level discharges that have [been] and will be discharged as a result of the TMI accident."

a. For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each effect listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

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c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

2-8 In alleging that the " low-level radiological discharges from Unit #1, in addition to ... high-level discharges ... as a result of the TMI accident, will have a significant adverse effect on the water quality in the Susquehanna," does TMIA contend that the low-level discharges associated with the normal operation of Unit 1 and the alleged high-level discharges resulting from the Unit 2 accident will have a greater total effect (i.e., a synergistic effect) on the water quality of the Susquehanna than the simple addition of the low-level discharges associated with the normal operation of Unit 1 to the alleged high-level discharges resulting from the Unit 2 accident? If not, set forth with precision and particularity the relationship which TMIA contends exists between the " low level radiological discharges from Unit #1" and the alleged "high level discharges that have [been) and will be discharged as a result of the TMI accident."

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents containing any evidence or information bearing upon or relating to the allegation

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

1804 310 2-9 Describe in detail the interrelationship which TMIA alleges between " low-level radiological discharges from Unit

1. 1" and the alleged "high-level discharges that have [been] and will be discharged as a result of the TMI accident," as they affect the water quality of the Susquehanna.

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

2-10 Describe the nature and source of the " additional discharges of radiation into the Susquehanna" which TMIA alleges would occur "(i] f Unit #1 were to reopen while decontamination of Unit #2 was continuing."

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

d. Does TMIA contend that these " additional discharges of radiation into the Susquehanna" will occur only if Unit I reopens before the decontamination of Unit 2 has been completed? If so, explain why the discharges will not occur if 1804 311

Unit 1 is not reopened until the decontamination of Unit 2 has been completed.

e. Are the " additional discharges of radiation into the Susquehanna" referred to in this interrogatory synonymous with the " additional low-level radiological discharges from Unit #1" described in 2-1, above? If not, explain the difference between the two terms as they are used in the respective allegations.

2-11 Describe the nature and source of the " discharges of radioactive wastewater into the Susquehanna" which TMIA alleges may occur during decontamination.

2-12 Identify all sequences of events which TMIA contends may result in " discharges of radioactive wastewater into the Susquehanna" during decontamination.

a. For each sequence of events listed, set forth each and every fact and the cource of each and every fact upon which the allegation is based.

b. For each sequence of events listed, identify all documents containing any evidence or information bearing upon or relating to the allegation,

c. For each sequence of events listed, identify all persons having any information or knowledge supporting or relating to the allegation.

2-13 Define the "present plan" for decontamination to which TMIA refers in the contention.

2-14 Describe in detail any and all " presently ascertain-able damage to the fish and wildlife in and around the river" which TMIA alleges to be a result of the accident at Unit 2.

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents containing any evidence or information bearing upon or relating to the allegation,

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

2-15 Describe the " pre 'tarch 28, 1979 levels" to which TMIA contends that Unit 2 should be decontaminated prior to consideration of reopening Unit 1.

Interrogatories on Contention No. 5 5-1 Identify every occasion on which TMIA contends that Met-Ed " negligently ...[or] wilfully violated NRC regulations concerning the safe operation of ... Unit #1 ... in that it ...

deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment af the integrity of the nuclear facility itself."

a. Define "necessary maintenance and repairs" as that term is used in the allegation,

b. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. Identify all documents containing any evidence or infor mation relating to or bearing upon the allegation.

1804 3i3

d. Identify all persons having any information or knowledge supporting or relating to the allegation.

5-2 Identify every occasion on which TMIA contends that Met-Ed " negligently ... (or) wilfully violated NRC regulations concerning the safe operation of ... Unit #2 ... in that it ...

deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment of the integrity of the nuclear facility itself."

a. Define "necessary maintenance and repairs" as that term is used in the allegation.

b. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. Identify all documents containing any evidence or information relating to or bearing upon the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation.

5-3 Identify every occasion on which TMIA contends that Met-Ed " allowed work orders to go undone in order to avoid shutting Unit #1 down to perform necessary maintenance."

a. Define "necessary maintenance" as that term is used in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, including Generation Corrective Maintenance System Job Tickets (Work Requests) -

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Three Mile Island [" Job Tickets"), containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation.

5-4 Identify every occasion on which TMIA contends that Met-Ed " allow [ed] work orders to pile up until refueling, at which time the licensee would attengt to do all the work required.'

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents, including Job Tickets, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

5-5 Does TMIA contend that it is inappropriate to defer maintenance and repairs until a plant outage?

a. Set forth each and every fact and the source of each and every fact relating to or bearing upon TMIA's conclusion.

b. Identify all documents, including Job Tickets, containing ary evidence or information relating to or bearing upon TMIA's conc.1sion.

c. Identify all persons having any information or knowledge supporting or relating to TMIA's conclusion.

1g04 315

d. If TMIA contends that it is inappropriate to defer all maintenance and repairs until a plant outage, identify the criteria which TMIA contends should be used to determine maintenance and repairs which can be deferred and that which cannot.

5-6 Identify every occasion on which TMIA contends that,

"[j]ust to complete essential maintenance in the short time available, employees were worked to a poin, where they were no longer effective because of fatigue."

a. Define " essential maintenance" as that term is used in the allegation.

b. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. Identify all documents, including Job Tickets, -

containing any evidence or information relating to or bearing upon the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation.

Interrogatories on Contention No. 6 6-1 Identify all " technical changes that may be demanded as a result of the accident at Unit #2," other than those cited in the Commission's August 9, 1979 Order and Notice of Hearing, with which TMIA contends Met-Ed does not have the financial capability to comply.

1804 316

a. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

b. Identify all documents containing any evidence or information relating to or bearing upon the allegation.

c. Identify all persons having any information o."

knowledge supporting or relating to the allegation.

6-2 Indicate all estimates which TMIA has of the cost to Met-Ed of complying with the " technical changes" identified in response to 6-1, above.

a. For each cost estimate listed, set forth each and every fact and the source of each and every fact relating to or bearing upon that cost estimate.

b. For each cost estimate listed, identify all documents containing any evidence or information relating to or bearing upon that cost estimate.

c. For each cost estimate listed, identify all persons having any information or knowledge supporting or relating to that cost estimate.

6-3 Identify all regulations of the NRC requiring the expenditure of additional sums of money for mandated design changes with which TMIA contends Met-Ed does not have the financial capability to comply,

a. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

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b. Identify all documents containing any evidence or information relating to or bearing upon the allegation,

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

6-4 Indicate all estimates which TMIA has of the cost to Met-Ed of complying with the NRC regulations identified in response to 6-3, above.

a. For each cost estimate listed, set forth each and every fact and the source of each and every fact relating to or bearing upon that cost estimate,

b. For each cost estimate listed, identify all documents containing any evidence or information relating to or bearing upon that cost estimate.

c. For each cost estimate listed, identify all persons having any information or knowledge supporting or relating to that cost estimate.

6-5 Identify all regulations of the NRC requiring the expenditure of additional sums of money for changes in the financial protection requirements of 10 C.F.R. Part 140 with which TMIA contends Met-Ed does not have the financial capability to comply.

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

_2a_ 1804 3i8

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

6-6 Indicate all estimates which TMIA has of the cost to Met-Ed of complying with the NRC regulations identified in response to 6-5, above.

a. For each cost estimate listed, set forth each and every fact and the source of each and every fact relating to or bearing upon that cost estimate.

b. For each cost estimate listed, identify all documents containing any evidence or information relating to or bearing upon that cost estimate.

c. For each cost estimate listed, identify all persons having any information or knowledge supporting or

, relating to that cost estimate.

6-7 Describe in detail the nature of Met-Ed's alleged

" energy obligations to the PJM interconnect."

6-8 Identify every occasion on which TMIA contends Met-Ed "has been unable to meet its energy obligations to the PJM interconnect" because of problems with Unit 2.

a. For each occasion listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

b. For each occasion listed, identify all documents containing any evidence or information relating to or bearing upon the allegation.

1804 319

c. For each occasion listed, identify all nersons having any information or knowledge supporting or relating to the allegation.

6-9 Describe in detail the manner in which TMIA contends that "the licensee's ability to borrow money" will be affected by "the licensee's deferred energy balance owed PJM."

a. Describe in detail the nature and amount of Met-Ed's alleged " deferred energy balance owed PJM."

b. Set forth each and every fact and the source of each and every fact relating to or bearing upon these allegations.

c. Identify all documents containing any evidence or i.nformation relating to or bearing upon these allegations.

d. Identify all persons having any information or knowledge supporting or relating to these allegations.

Interrogatories on Contention No. 7 7-1 Identify the design basis accidents, classes one through eight, which TMIA contends " licensee will be unable to adequately deal with ... if one should occur at Unit #1 while decontamination continues at Unit #2."

a. For each accident listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

1804 320

b. For each accident listed, identify all documents containing any evidence or information relating to or bearing upon the allegation.

c. For each accident listed, identify all persons having any information or knowledge supporting or relating to the allegation.

7-2 Estimate the quantity of radioactive wastewater requiring storage which TMIA contends will be generated by each of the accidents identified in response to 7-1, above.

a. For each estimate listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

b. For each estimate listed, identify all documents containing any evidence or information relating to or bearing upon the allegation.

c. For each estimate listed, identify all persons having any information or knowledge supporting or relating to the allegation.

7-3 Describe the mechanism by which TMIA contends that each of the accidents identified in response to 7-1, above, will generate the quantity of radioactive wastewater requiring storage as estimated in response to 7-2, above.

7-4 Explain the basis for TMIA's contention that "the wastewater storage capability of Unit il if an accident were to occur, would be insufficient, since a large portion of this capacity may ultimately be committed to the safe decontamina-tion of Unit #2."

a. Specify the portion of the wastewater storage capacity of Unit 1 which TMIA contends "may ultimately be committed to the safe decontamination of Unit #2."

b. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. Identify all documents containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation.

7-5 Does TMIA contend that none of the wastewater storage capacity of Unit 1 can be committed to "the safe decontamina-tion of Unit #2" while Unit 1 is in operation?

a. cat forth each and every fact and the source of each and every fact relating to or bearing upon TMIA's conclusion.

b. Identify all documents containing any evidence or information relating to or bearing upon TMIA's conclusion.

c. Identify all persons having any information or knowledge supporting or relating to TMIA's conclusion.

7-6 Identify all accidents which TMIA contends might occur "at Unit #2 during decontamination which would result in the diversion of all Unit #1 storage capacity to Unit #2, thereby leaving Unit #1 unable to cope with any type of 1804 522

accident that would produce abnormal amounts of radioactive wastewater."

a. For each accident listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

b. For each accident listed, identify all documents containing any evidence or information relating to or bearing upon the allegation.

c. For each accident listed, identify all persons having any information or knowledge supporting or relating to the allegation.

7-7 Estimate the quantity of radioactive wastewater requiring storage which TMIA contends will be generated by each of the accidents identified in response to 7-5, above.

a. For each estimate listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each estimate listed, identify all documents containing any evidence or information bearing upon or relating to the allegation.

c. For each estimate listed, identify all persons having any information or knowledge supporting or relating to the allegation.

7-8 Describe the mechanism by which TMIA contends that each of the accidents identified in response to 7-5, above, will generate the quantity of radioactive wastewater requiring storage as estimated in response to 7-6, above.

7-9 Define " abnormal amounts of radioactive wastewater" as that term is used in the allegation.

7-10 Specify what TMIA contends is " f sufficient] storage capacity on the island to deal with a Unit #2 accident at Unit

1. 1."

a. Set forth each and every fact and the source of each and every fact relating to or bearing upon the figure specified.

b. Identify all documents containing any evidence or information relating to or bearing upon the figure specified.

c. Identify all persons having any information or knowledge supporting or relating to the figure specified.

7-11 Describe in detail the nature of the " unreasonable and unacceptable risk to the public health and safety" which TMIA contends will be posed if Unit 1 is reopened before Unit 2 has been completely decontaminated.

a. Set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

b. Identify all documents containing any evidence or information relating to or bearing upon the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

_34_ 1804 324

7-12 Define with specificity the term " safely decon-taminated", as that term is used in the allegation in reference to Unit 2.

7-13 Does U1IA contend that the physical separation of Units 1 and 2, as described in the TMI-l Restart Report, pages 7-1 through 7-6, and Supplement 1, Part 2, questions 52 and 54, is inadequate to resolve the concerns identified in TMIA Contention No. 7? If so:

a. Describe in detail the inadequacies of the physical separation proposed by Met-Ed.

b. For each inadequacy listed, set forth each and every fact and the souce of each and every fact relating to or bearing upon the allegation.

c. For each inadequacy listed, identify all documents containing any evidence or information relating to or bearing upon the allegation.

d. For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to

, the allegation.

7-14 Does TMIA contend that the storage capacities and capabilities of Units 1 and 2, as described in the TMI-1 Restart Report, pages 7-6 through 7-llc, and Supplement 1, Part 2, questions 53 and 54, re inadequate to resolve the concerns identified in TMIA Contention No. 7? If so:

1804 325

a. Describe in detail the inadequacies of the storage capacities and capabilities proposed by Met-Ed.

b. For each inadequacy listed, set forth each and every fact and the souce of each and every fact relating to or bearing upon the allegation.

c. For each inadequacy listed, identify all documents containing any evidence or information relating to or bearing upon the allegation.

d. For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to the allegation.

Interrogatory 8 8-1 With respect to each individual whom TMIA intends to call as a witress in this proceeding:

a. Identify by name, address and affiliation each such individual;

b. State the educational and professional background of each such individual, including occupation and institutional affiliations, publications and papers;

c. Identify the contention as to which each such individual will testify;

d. Describe the nature of the testimony which will be presented by each such individual, including an identifica-tion of all documents which the individual will rely upon in the testimony.

1804 326

e. Identify by court, agency or other body, proceeding, date and subject matter of all prior testimony by each such individual.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: A '

//#ff/ '

//

' feory'e F. Tyowbridge Counsel for Licensee /

1800 M Street, N.W.

Washington, D.C. 20036 (202) 331-4100 1804 327

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Interrogatories To Intervenor Three Mile Island Alert, Inc.",

dated January 14, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 14th day of January, 1980.

~V M 'm M //

Go6rge F.'Trowbridg'e Dated: January 14, 1980 i804 .328

. s .

CNITED STATES OF A. ERICA NUCLEAR REGULATORY CCMMISSION BEFORE THE ATCMIC SAFI""? AND LICENSING SOARD -

In the Matter of )

)

METROPCLITAN EDISCN COMPANY ) Occket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SdAv1CE LIST Ivan W. Smith, Esq"i e Jchn A. Levin, Esquire

("' M 2.n Assistant Ccunsel Atcmic Safety and Licensing Pennsylvania Public Utility Board Panel Cc==ission U.S. Nuclear Regulatory P. O. Ecx 3265 .

Comnissics Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire .

Dr. Walter E; Jordan Assistant Attorney General Atemic Safety and Licensing Ccm=cnwealth of Fransylvania Board Panel 505 Executive Ecuse 881 West Guter Drive P. O. Ecx 2357 Cak Ridge,. Tennessee 37830 Earrisburg, P=" sylvania 17120 Dr. Linda W. Little Robert L. Knupp, Esquire Atcmic Safety and Licensing Assistant Soliciter Scard Panel County of Daupe'd" 5000 Ee"4 tage Drive P. O. Box P Raleigh, North Carolina 27612 407 North Front Street Harrisburg, Pennsylvania 17108 James R. Tourtellotte, Esquire (41 office of the Executive Legal John E. Minnich Director Chai m , Dauphin County scard U.S. Nuclear Regulatory of Ccmmissioners Ccmmission Dauphin County Courthouse Washington, D.C. 20555 Front and Market Streets Harrisburg, Pennsylvania 17101 Decketing and Service Section (21)

Office of the Secretary Walter W. Cchen, Esquire U.S. Nuclear Regulatory Consumer Advocate Comnission Depart =ent of Justice.

Washingten, D.C. 20555 14th Ploor, Strawberry Square Harrisburg, Pennsylvania 17127 1804 329

Jc:da: D. C"- 4 gham, Isq 4 e Kare Attc ey fc: Newhe_._f Tcw- +4 p Shelden, Esq-ize Shelden, Ea==cn & Weiss C.M.I. Steering Cc 4 ttee Suite 506 2320 Nc th Sec==d Street

=n risburg, ?=- sylvn 4 a 1725 Eye Street, N.W.

17110 Wash 4 gton, D.C. 20006 Thecdcre A. Ja'er, Isq 4 e schert Q. Fellard Widofd Reager Se2%cwit: & Adler Chesapeake Energy Alf4= ce P. O. Sex 1547 609 Mcntpelier Street "n risburg, Pe= sylvania 17105 Sal *4 cre, Maryland 21218 "71yn Weiss, Esqnd e c'"" cey Kepfc d Sheldc=, E' c= a Weiss Jndi th E. Jch=s nd

• Suite 506 Z v4:===en:21 Ccali"ic en 1725 Eye Street, N.W. Nuclear Pcwer Was5d gt==, D.C. 20006 433 0:lando Ave =ne Steven C State College, ?=--sylvania 1680 Shcily 304 Scuth Market St: eet y= rin I. Lewis Me#~' d esburg, Pa~ sfivn 4 = 17055 6504 3raddc d ma-=ce .

Ec11y S. Keck Pb4'adelphia, Po--sylvania 19149 Legislation Ch'irman a Ma.--jorie M. Aa=cdt Anti-Nuclear Group Represent,ng R. D. 5 York 245 West Philadelphia Street Ccatesville, Pa- sylvan'ia 19320' York, Pennsylvania 17404 i

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