ML19305D082

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Response to Aamodt Family 800216 First Set of Interrogatories Re Restart Proceeding.Includes Info Re Agricultural Emergency Plan & Other Related Agricultural Issues.Re Zahler 800331 Forwarding Ltr to Mm Aamodt Encl
ML19305D082
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 03/31/1980
From: Trowbridge G, Zahler R
METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Aamodt M
AFFILIATION NOT ASSIGNED
Shared Package
ML19305D049 List:
References
NUDOCS 8004140045
Download: ML19305D082 (5)
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Text

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

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart) .

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S RESPONSE TO THE FIRST SET OF INTERROGATORIES FROM THE AAMODT FAMILY (DATED FEBRUARY 16, 1980)

INTERROGATORY NO. 1 Is there an agricultural plan referred to in Section 4, Annex E Emergency Planning, Response to Restart as Department of Agricul-ture Plan Fixed Nuclear Facility Incident Plan? If so; provide.

RESPONSE

It is Licensee's understanding that such a plan does exist.

The Department of Agriculture has confirmed the agricultural plan's existence and has stated that it is presently undergoing revi-sion. Licensee has not yet received a copy of the plan, but when it does a copy will be placed in Licensee's Discovery Reading o

Room.

INTERROGATORY NO. 2 This agricultural plan is noted as " Limited Distribution under Separate Cover".

(a) Why is distribution limited? l (b) On what basis was limited distribution decided? .

8004140045i ,

r-O (c) After my request on January 31, 1980 to obtain a copy of this plan, what efforts did you make to fulfill this request?

RESPONSE

(a) The decision was made by the Commonwealth oi Pennsyl--

vania. Licensee has no knowledge of the basis for that decision.

(b) See Licensee's response to Interrogatory No. 2(a).

(c) See cover letter.

INTERROGATORY NO. 3 Provide names and credentials of those members of Met Ed who are working with the Department of Agriculture on this plan.

RESPONSE

To date none of Licensee's personnel.has worked with the Department of Agriculture in developing the agricultural plan.

Licensee works with offsite emergency response agencies by attend-ing PEMA meetings which involve Licensee, state and' local officials (of which Department of-Agriculture is a part) for the purpose of coordina' ting emergency plans. Licensee anticipates that it will participate in the review of the revised agriculture plan upon its completion through meetings similar to those attended in the past.

INTERROGATORY NO. 4 Do you have any figures on the value of the livestock, farmland and agricultural products included in the ten mile and fifty mile EPZs of TMI?

(a) When were these figures obtained by you?

(b) From whom did you obtain them?

RESPONSE ,

Licensee does not have these figures. This' responsibility

, .- 's lies with the Department of Agriculture. It is Licensee's under-standing, from talking to the Department of Agriculture, that figures on livestock, farmland and agricultural products do exist but that they may not be broken down in terms of the 10-mile and 50-mile EPZ's.

1 Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: m ._ h //

'$orp F4 T1-dwbridge /

Robert E. Zahler Dated: March 31, 1980

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March 31, 1980 Ms. Marjorie M. Aamodt R. D. 5 a

Coatesville, Pennsylvania 19320 Re': Three Mile Island Unit 1 Docket No. 50-289 (Restart)

Dear Ms. Aamodt:

I enclose Licensee's responses to your first set of inter-rogatories, dated February 16, 1980. Copies of signed affi-davits for these responses are not enclosed, but will be for-

, warded shortly.

Interrogatory No. 2 (c) seeks information on the efforts i made by Licensee to obtain and send to you a copy of the Depart-ment of Agriculture's section of the State Emergency Plan.

Since I undertook to make the necessary inquiries, I believe  ;

it appropriate that I respond to your question.

On January 31, 1980, I received a telephone call from a secretary at GPU Service Corporation. She informed me that you initially had called Gilbert Associates seeking a copy of the Agriculture Plan. Apparently, Gilbert Associates suggested that you call GPU Service Corporation. I attempted to return your call that day, but received no answer. On February'1, 1980, I spoke with you about the Agriculture Plan. At that time I informed you that Licensee did not have a copy of the Agriculture Plan, that I was not sure as to the status of the

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SHAW, PITTMAN, POTTS & TROWORIDGE Ms. Marjorie M. Aamodt March 31, 1980 Page Two 1 Plan, but that if I found out anything more about the Plan I would call you back.

Thereafter, I spoke with J. David Bigbee, a consultant to Licensee working on the Emergency Plan. Mr. Bigbee confirmed my general understanding about the Agriculture Plan, but said that he would check further with state personnel. A few '

days later, Mr. Bigbee called to tell me that he had spoken with Mr. Charles Crowe, a member of the Pennsylvania Emergency Management Agency. Mr. Crowe indicated that the Agriculture Plan was under revision and therefore was not presently avail-able. This information was consistent with the information that I had relayed to you on February 1, 1980. I During the prehearing conference on February 13, 1980, we spoke again about this matter. At that time I also spoke with ,

Ms. Karin Carter, the Commonwealth's attorney, to confirm.that +

my understanding was still correct. Over the lunch break Ms.

Carter checked with state personnel and later indicated to me that the Agriculture Plan was still being revised. At the end of the day I passed this information along to you.

I see from the Commonwealth's response to your interroga- ,

tories that the Agriculture Plan has been completed, and a copy has been sent to you. ,

Sincerely yours, Robert E. Zahler Enclosure cc: Service List REZ:clg i

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