ML19260E062
| ML19260E062 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/18/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Aamodt M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8002130243 | |
| Download: ML19260E062 (9) | |
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Dated:
January 18, 1980 si
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UNITED STATES OF AMERICA ep 5'
NUCLEAR REGULATORY COMMISSION 4
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BE70RE THE ATOMIC SAFETY AND LICENSING BOA
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In the Matter of
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METROPOLITAN EDISCN COMPANY
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Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR MARJORIE M.
AAMODT These interrogatories are filed pursuant to 10 C.F.R.
S2.740b, which requires that the interrogatories be answered separately a:.2 fully in writing and under oath or affirmation.
Licensee requests that Intervenor Marjorie M. Asodt ("Ms.
Aamodt") answer each of these interrogatories within the time specified.in 52.740b to the extent that responsive information is presently available to her.
With respect to those inter-rogatories for which complete and responsive information is not available to Ms. Aamodt, Licensee requests that revised answers be provided prior to the close of the discovery period estab-lished in the Licensing Board's December'18, 1979 First Special Prehearing Conference Order.
When knowledge or information of Ms..Aamodt is -requested, such request includes knowledge or 8002230 3'
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information of "co-intervenors" Norman O. and Susan E.
Aamodt
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and, unless privileged, their attorneys (if any).
The following definitions apply to each of the inter-e rogatories below:
A.
" Document" means all writings and records of every type including, but not limited to memoranda, tapes, corrc-E p
spondence, reports, surveys, tabulations, charts, books, I
pamphlets, photographs, maps, bulletins, minutes, notes, diaries, logs, testimony, speeches, articles, transcripts and all other records, written, electrical, mechanical or other-
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wise.
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 posi-
~~E-tion; (2)
With respect to a document, the type of document EE ME (e.g., letter, record, list, memorandum, memorandum of tele-
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phone or face-to-face conversation, etc.), date of the docu-ment, title of the document, subject of the document, name of person who prepared the document, and name of person for whom
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the document was prepared or to whom it was delivered.
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Interrogatories on Contention No. 8 8-1 Do you contend that the physical separation of Units 1 and 2, as described in the TMI-1 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 Aamodt Contention No. 87 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 source of each and every fact relating to oc bearing upon the allegation.
c.
For each inadequacy listed, identify all documents, and the particular parts thereof, containing any evidence or infocmation 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.
8-2 Do you contend that the safety evaluation performed by the NRC Staff with respect to the physical separation of Units 1 and 2, as cescribed in the January 11, 1980 Status Report on the Evaluation of Licensee's Comoliance with the NRC Order dated August 9, 1979
(" Status Report"), pages C4-1 through C4-16, is inadequate to resolve the concerns idantified in Aamodt Contention No. 8?
If so:
a.
Describe in detail the inadequacies of the physical separation safety evaluation oerformed by the NRC Staff.
b.
For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.
c.
For each inadequacy listed, identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.
d.
For.ach inadequacy lis*.ed, identify all persons having any information or knowledge supporting or relating to the allegation.
8-3 Do you contend that the storage capacities and capabilities of Units 1 and 2, as described in the TMI-1 Restart Report, pages 7-6 through 7-11c, and Supplement 1, Part 2, questions 53 and 54, are inadequate to resolve the concerns identified in Aamodt Contention No. 8?
If so:
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 source of each and every fact relating to or bearing upon the allegation.
y c.
For each inadequacy listed, identify all e
documents, and the particular parts thereof, containing any
[r evidence or information relating to or bearing upon the
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allegation.
d.
For each inadequacy listed, identify all persons l
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having any information or knowledge supporting or relating to i
the allegation.
i 8-4 Do you contend that the safety evaluation performed by the NRC Staff with respect to Unit 1 and 2 storage capacities, as described in the Status Report, pages C5-1 through C5-14, is inadequate to resolve the concerns identified in Aamodt Contention No. 8?
If so:
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a.
Describe in detail the inadequacies of the storage capacity safety evaluation performed by the NRC Staff.
b.
For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.
c.
For each inadequacy listed, identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.
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d.
For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to the allegation.
8-5 Describe in detail the " personal experience with radwaste disposal" to which you refer in Contention No. 8.
Interrogatory 13 13-1 With respect to each individual whom you intend to call as a witness in this proceeding:
a.
Identify by name, address and affiliation each such individual; b.
State the educational and professional back-ground 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 w..ich will be presented by each such individual, including an identifica-tion of all documents which the individual will rely upon in the testimony.
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 j M/
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W3eotge F'.
Trowbridge
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' Counsel for Licensee /
1800 M Street, N.W.
Washington, D.C.
20036 (202) 331-4100 l I
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RELATED CORRESPO.'QL'. CE N
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UNITED STATES OF AMERICA d)
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NUCLEAR REGULATORY COMMISSION
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BEFORE THE. ATOMIC SAFETY AND LICENSING BOA In the Matter of
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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 Marjorie M. Aamodt, dated January 18, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 18th day of January, 1980.
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Dated:
January 18, 1980 i
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UNIT.ED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
i METROPOLITAN EDISON CCMPANY
)
Docket No. 50-289
[
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
k 1
Ivan W.
Smith, Esquire John A.
Levin, Esquire
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Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Board Panel Commission U.S. Nuclear Regulatory P. O. Box 3265
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Commission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Karin W.
Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel
. L.,
881 West Outer Drive 505 Executive Hovr>e P. O. Box 2357 e
Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17120
- nupp, squire j
Dr. Linda W. Little er ss tor Atomic Safety and Licensing u
Da h r, Board Panel P. O. Box P 5000 Hermitage Drive Raleigh, North Carolina 27612 407 North Front Street b
Harrisburg, Pennsylvania 17108
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James R. Tourtellote, Esquire (4)
John E. Minnich Office of the E:cecutive Legal Director Chairman, Dauchin County Board
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of Commissioners U.S. Nuclear Regulatory Commission Dauphin County Courthouse Washington, D.C.
20555 Front and Market Streets f
Harrisburg, Pennsylvania 17101 Docketing and Service Section (21)
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Office of the Secretary Walter W.
Cohen, Esquire U.S. Nuclear Regulatory Consumer Advocate Commission Department of Justice Washington, D.C.
20555 14th Floor, Strawber y Square Harrisburg, Pennsylvt 11a 17127 I
Jordan D. Cunningham, Esquire Karen Sheldon, Esquire Attorney for Newberry Township Sheldon, Harmon & Weiss T.M.I. Steering Committee Suite 506 2320 North Second Street 1725 Eye Street, N.W.
Harrisburg, Pennsylvania 17110 Washington, D.C.
20006 Theodore A. Adler, Esquire Robert Q. Pollard Widoff Reager Selkcwitz & Adler Chesapeake Energy Alliance P. O. Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn Weiss, Esquire Chauncey Kepford Sheldon, Harmon'& Weiss Judith H.
Johnsrud suite 506 Environmental Coalition on 1725 Eye Street, N.W.
Nuclear Power Washington, D.C.
20006 433 Orlando Avenue State College,-Pennsylvania 16801
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Steven C.
Sholly 304 South Market Street Marvin I. Lewis Mechanicsburg, Pennsylvania 17055 6504 Bradford Terrace Philadelphia, Pennsylvania 19149
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Holly S. Keck Legislation Chairman Marjorie M.
Aamodt
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Anti-Muclear Group Representing R. D.
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York Coatesville, Pennsylvania 19320 245 West Philadelphia Street York, Pennsylvania 17404 a
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