ML19260D937

Third Set of Interrogatories.Includes Questions Re Excess Radiation Releases Into Air & Into Susquehanna River During First Quarter of 1979.Certificate of Svc Encl

ML19260D937
Person / Time
Site:	Three Mile Island
Issue date:	01/22/1980
From:	Adler T THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:	METROPOLITAN EDISON CO.
References
NUDOCS 8002120636
Download: ML19260D937 (7)

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UNITED STATES OF AMERICA g 3g25W@* _2 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD m P

, c, In the Matter of  :

METROPOLITAN EDISON COMPANY  : Docket No. 50-289 (Three Mile Island Nuclear  : (Restart)

Station, Unit No.1)  :

INTERROGATORIES OF INTERVENOR THREE MILE ISLAND ALERT, INC.

TO LICENSEE (Third Set)

Three Mile Island Alert, Inc., by its attorneys, Widoff, Reager, Selkowitz and Adler, P.C., hereby files interrogatories pursuant to 10 C.F.R., Section 2.740(b). These interrogatories are deemed to be continuing, and shall be supplemented by Licensee when and if additional or corrective information is obtained.

1. Have there been any releases of radiation into the air during the first quarter of 1979, that exceeded

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the daily average composite releases of the prior quarter?

1950 345 h 8002120 $Y

2. If so, state:

(a) the type of release (b). the cause of the increased release (c) the remedial measures taken (d) whether the Licensee received any warnings or fines by the NRC and pr:;ide copies of any such warnings or fines

3. Please provide the same information requested in Interrogatories 1 and 2, with respect to radioactive releases into the Sur.quehanna River.

4. Please provide the same information requeated in Interrogatories 1, 2.and 3 for the third and fourth quarters of 1978.

1950 346

5. In Licensee's supplemental response to Interrogatory 6,

' you state that " concentrations of radioactive noble gases would have exceeded values specified in 10 CFR Part 20 in only a few off-site locations..." Please identify these locations.

6. What is TDR-TMI-ll6, ccferred to in your answer to Interrogatory 8 (First Set)?

7. With respect to Licensee's reponse to Interrogatory 5 (Second Set), how manv iodine gasecue effluent nonitors were operating at TMI-2 at the time of the accident?

8. Where are the monitors referred to in Interrogatory 7 hereof located?

1950 347

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9. For the period March 28 - April 11,1979, were there any iodine readings that exceeded the quarterly composite of iodine releases for the fourth quarter of 19787

10. If so:

. (a) State the cause of the release.

(b) State the remedial measures taken.

(c) Provide copies of the readings indicating these releases.

11. With respect to your response to Interrogatory 12 (Second Set), when were the portable monitors battery-9 checked, i.e., date and time each monitor was checked.

1950 348

12. Please provide the names and addresses of the individuals responsible for battery testing the monitors during the period March 28 - April 5, 1979.

13. Please provide the results of each battery test for the period stated in Interrogatory 12.

14. In its response to Interrogatory 31 (Second Seti, Licensee states that eight (8) facilities associated with TMI-l are still being used to deal with the clean-up of the accident at TMI-2. When will each of the eight (8) facilities listed in Attachment A to Interrogatory 31 no longer be needed to deal with the accident?

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15. After these fac.llities are no longer needed in connection with TMI-2, will they be contaminated?

16. If so, how long will it take for them to be decontamina'ed?

Respectfully submitted, WIDOFF GER ,L WITZ & ADLER,P.C.

By:

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/Theodore A. Adler Dated: January 22, 1980 1950 350 CERTIFICATE OF SERVICE, I do hereby certify that I served a true and correct copy of the foregoing document on the below listed parties by first-class mailing:

Ivan W. Smith, Esquire Atomic Safety & Licensing Board U.S. Nuclear Regu)atory Commission Washington, D.C. 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tenn. 37380

- Dr. Linda W. Little 5000 Hermitage Drive Raleigh,N.C. 27612 George F. Trowbr.i Gge, Esquire Shaw, Pittman, Poets & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 f

/The~odore A."Adler g- N'

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Dated: January 22, 1980 -

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