ML19291C502

Response by Consumer Advocate of State of PA to NRC First Set of Interrogatories.Questions Not Applicable Due to Lack of Participant State Status.W/Affidavit & Certificate of Svc

ML19291C502
Person / Time
Site:	Three Mile Island
Issue date:	01/11/1980
From:	Blask J PENNSYLVANIA, COMMONWEALTH OF
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8001240509
Download: ML19291C502 (7)

Text

. .

UNITED S'"ATES OF A5 ERICA NUCLEAR REGUIA'IORY COGIISSION BEFORE T1E A'IOMIC SAFE 1Y AND LICENSING BOAPD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island hbclear )

Station, Unit No. 1) )

. CONSUMER ADVOCATE OF TIE COGIONWEALTH OF PENNSYLVANIA'S RESPONSE 'IO FIRST SET OF NRC STAFF INTERROGA'IORIES Interrogatories With regard to each of yc,w adnitted issues, provide the following information:

1. Identify the individual (s), if any, that you intend to present as witnesses in this proceeding on the subject matter of each of your issues. The identification should include the individual's name, affiliation, and a summary of the educational and professional background of that individual.

2. Provide a reasonable description of the substance of the testinony of any witness (es) that you intend to have testify with regard to each of your issues, including an identification of all documents that will be relied upon in that testinony.

3. Following the substantive response to each of the subsequent inter-rogatories posed by the Staff, identify all docu:mnts and studies relied upon by you in providing the answers to that interrogatory.

1793 177 8001 240 g

The identification should be specific to the portion of the document or study relied upon. Studies shall include observations, calcula-tions, literature and other types of work, whether recorded in writing or not, which consist of an e.xamination or analysis of a pheoncunenon.

4. Following the substantive response of each of the subsequent inter-rogatories posed by the Staff, identify by name and affiliation each individual who has knowledge which served as the basis for the answer to that interrogatory.

Response

The Consumer Mvocate of the Comnonwealth of Pennsylvania has been granted an opportunity to participate in this proceeding as an interested State Agency in accordance with 10 CFR S2.715(c), which provides that such an agency will be afforded "a reasonable opportunity to participate... without requiring [the agency] to take a position with respect to the issue." As a result, the Consumer Mvocate has no " admitted issues" to which it could refer in response to the general interrogatories propounded by the NRC Staff.

The Consumer Mvocate reserves its right under 10 CFR S2.715(c) to participate fully in this proceeding. That participation will be substantially affected, however, by resolution of certain issues currently under consideration by the Board and/or the Nuclear Regulatory Cmmission, particularly the question of NRC funding for intervenors.

In view of the above, the Consumer Mvocate provides the following answers to the general interrogatories of the NRC Staff.

1793 178

1. These individuals cannot be identified at this time.

2. Not applicable.

3. Not applicable.

4. Not applicable.

The Consumer Mvocate will provide nore complete answers to the general interrogatories of the NRC Staff at such time as the information requested becanes available in recognition of its duty to supplement under 10 CFR S2.740(e) .

Respectfully subnitted, Awsa d4 Jerane K. Blask Assistant Consumer Mvocate Department of Justice Office of Consumer Myocate 1425 Strawberry Square, 14th Floor Harrisburg, PA 17120 (717) 783-5048 DATED: January ll, 1980 1793 179

UNITED STATES OF AMERICA NUCLEAR REGUIATORY CCl411SSION BEFORE THE ATOMIC SAFEI"I AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON CCMPANY ) Docket No. 50-289

) (Restart)

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF JEROME K. BLASK Ccmnonwealth Of Pennsylvania )

) SS County of Dauphm )

JEROME K. BLASK, being duly sworn according to law, desposes and says that he is an ASSISTANT CONSUMER ADVOCATE IN THE PENMVANIA OFFICE OF CONSUMER ADVOCATE; that the information contained in Consunnr Advocate's response to NRC Staff General Interrogatories Nos. 1, 2, 3 and 4 are true and correct to the best of his knowledge, infomation and belief.

bd m a ,  :

Jerone K. Blask Assistant Consuner Advocate Office of Consumer Advocate Sworn to and subscribed

.lefore me this // d' day of January,1980

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, ;crARYp0BL1C p seMs. r , c:w., ma n, o,n . 2. 3s2 r, . <

• s,  ! 3 (, n f 1793 180

!NITED STATES OF AEM NUM REGUIATORY CGMISSION BEFORE THE A'ICMIC SAFETY AND LICENSING BOARD In the Matter of )

)

ME7fBOPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

Lt.KruICATE OF SERVICE I, JERGE K. BIASK, hereby certify that I have served copies of the Consumer Advocate of the ConTaonwealth of Pennsylvania's Response To First Set Of NRC Staff Interrogatories upon those persons on the attached Service List by deposit with the United States Postal Service at 813 Market Street, Harrisburg, Pennsylvania 17105, postage paid, this llth day of January,1980.

.// a/

h.s,'? w! / ,) , x Jerotm K. Blask Assistant Consumer Advocate DATED: January ll, 1980 U93 'l81

UNITED STATES OF AMERICA NUCLEAR REGUIATORY CObD1ISSION BEFORE THE ATOMIC SAFEIY AND LICENSING BOARD In the Matter of  :

MEI'ROPOLITAN EDISON  :

COMPANY, et al. ~

Docket No. 50-289 (Restart)

( M ree Mile Island, Unit 1)  :

Ivan W. Smith, Esq. Ms. Frieda Berryhill, Chairman Atanic Safety & Licensing Board m alition for Nuclear Power U.S. Nuclear Regulatory Cbmmission Plant Postponement Washington, DC 10555 2610 Grendon Drive Wilmington, DE 19808 Dr. Walter H. Jordan Atonic Safety & Licensing Board Mr. Pobert Q. Pollard 881 W. Outer Drive Chesapeake Energy Alliance Oak Ridge, TN 37830 609 bbntpelier Street Baltinore, MD 21218 Dr. Linda W. Little 5000 Hermitage Drive Karin W. Carter, Esq.

Paleigh, NC 27612 Assistant Attorney General 505 Executive House Secretary P.O. Box 2357 Nuclear Regulatory Comnission Harrisburg, PA 17120 Washington, DC 20555 Ellyn P. Weiss, Esq. (UCS)

George F. Trowbridge, Esq. Sheldon, Haraon, Poisman & Weiss Shaw, Pittman, Potts & Trowbridge 1725 I Street, hW, Suite 506 1800 M Street, N.W. Washington, DC 20006 Washington, D.C.

Chauncey Kepford, Esq.

Counsel for NRC Staff Environmental Coalition on Office of Executive Ingal Director Nuclear Power U. S. Nuclear Regulatory Commission 433 Orlando Avenue Waslungton, D.C. 20555 State College, PA 16801 Ms. Marjorie M. Aanodt Ibbert L. Knupp, Esq.

R.D. #5 Assistant Solicitor (batesville, PA 19320 County of Dauphin P.O. Box P, 407 N. Front Street Ms. Holly S. Keck, Ing. Chairman Harrisburg, PA 17108 Anti-Nuclear Group Representing York (ANGRY) Mr. Marvin.I. Irwis 245 W. Philadelphia Street 605 Bradford Terrace York, PA 17404 Philadelphia, PA 19149 1793 182

Jordan D. Cunningham, Esq.

Fbx, Farr & Cunningham 2320 North Second Street Harrisburg, PA 17110 Karin P. Sheldon, Esq. (PANE)

Sheldon, Harmon, Ibisman & Weiss 1725 I Street, N1, Suite 506 Washington, DC 20006 John A. Ie/in, Esq.

Assistant Counsel Pa. Public Utility Commission Poom G-28, North Office Building Harrisburg, PA 17120 Mr. Steven C. Sholly 304 South Market Street Mechanicsburg, PA 17055 Theodore Mler, Esq.

Attorney for Three Mile Island Alert, Inc. (EIIA)

P.O. Box 1547 Harrisburg, PA 17105 Hon. Mark Cohen 512 E-3, Fhin Capitol Building' Harrisburg, PA 17120 Mr. Thctnas Gerusky Bureau of Radiation Protection Department of Environmental Pesources P.O. Box 2063 Harrisburg, PA 17120 J. G. Herbein, Vice President Metropolitan Edison Company P.O. Box 542 Peading, PA 19603 i/93 183

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