ML19305C887

Objections to Interrogatories 1,5 & 6 Re Intervenor TMI Alert,Inc Seventh Set of Interrogatories.Social Security Numbers of Former Employees Deemed Irrelevant. Certificate of Svc Encl

ML19305C887
Person / Time
Site:	Three Mile Island
Issue date:	03/17/1980
From:	Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004100566
Download: ML19305C887 (5)

Text

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• March 17, 1980 l

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 1 ) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )-

e j i LICENSEE'S OBJECTIONS TO INTERVENOR  :

TMIA'S SEVENTH SET OF INTERROGATORIES Licensee objects to the following interrogatories included in Intervenor Three Mile Island Alert, Inc. (TMIA)'s j Seventh Set of Interrogatories: '

l Interrogatory No. 1.

TMIA requests the social security number of certain former employees of Licensee. Licensee has already given to TMIA the last known address of each of these employees. The personal information which TMIA now seeks in Interrogatory No. I was given to Licensee by its former employees

.at the initiation of employment, solely for employment purposes.

Licensee's former employees did not divulge this information to Licensee with any awareness or concurrence that it would be sub-ject to public use. Furthermore, the social security numbers -

of former employees are irrelevant to the resolution of the issues in this proceeding. Consequently, such information is not.

properly the subject of discovery requests to Licensee and, gen-erally, is beyond the scope of discovery.

80041oo Q

Interrogatory No. 5. TMIA requests the names, addresses, and social security numbers of employees in specified departments.

at Three Mile Island (Units 1 and 2) who left Licensee's employ-ment after March 28, 1979. Licensee objects to furnishing the social security numbers of the referenced employees for the rea-sons stated in Licensee's objections to Interrogatory No. 1. ,

3 Interrogatory No. 6. TMIA requests copies of all exit interview reports or sheets and/or all other written materials relating to the departure of employees in specified departments at Three Mile Island (Units 1 and 2) who left Licensee's employ-ment af ter March 28, 1979. Licensee cannot provide to TMIA the termination questionnaire forms completed by its former employees without violating its commitment, as set forth on the first page of the questionnaire, that "Any information you provide will be kept confidential". Licensee therefore objects to the disclosure of these documents.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

[) ,,/ f. # J $.

Ernest L. Blake, Jr.

Dated: March 17, 1980.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s 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 Objections to Intervenor TMIA's Seventh Set of Interrogatories" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 17th day of March, 1980'.

f,w/ AMA fl.

Ernest L. Blake, Jr.

Dated: March 17, 1980.

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

) ,

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 f

) (Restart)  :

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm.

Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555

• Karin W. Carter, Esquire

1. Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 681 West Outer Drive Harrisburg, Pennsylvania 17120 i Oak Ridge, Tennessee 37830 J

John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners >

Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 F

James R. Tourtellotte, Esquire (4) Walter W. Cohen, Esquire

, Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square 4

Harrisburg, Pennsylvania 17127 Docketing and Service Section (21)

Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 t

- - - < . ,.e , ,, - - ,

. Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for Peoole Acainst

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T.M.I. Steering Committee Nuclear Enercy' 2320 North Second Street Sheldon, Harmod & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Escuire Widoff Reager Selkowitz & Adler Robert O. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Escuire Chauncey Kepford Attorney for the U5 ion of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Sheldon, Harmon & Weiss Nuclear Power 1725 Eye Street, N.W., Suite 506 433 orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 1680)

Steven C. Sholly Marvin I. Lewis

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304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149-Gail Bradford Marjorie M. Aamodt R. D. 5 Holly S. Keok Coatesville, Pennsylvania 19320 Legislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street '

York, Pennsylvania 17404

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