ML19309D051
| ML19309D051 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/02/1980 |
| From: | Smith I Atomic Safety and Licensing Board Panel |
| To: | METROPOLITAN EDISON CO., UNION OF CONCERNED SCIENTISTS |
| References | |
| NUDOCS 8004100024 | |
| Download: ML19309D051 (2) | |
Text
Bd 4/2/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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APR 31980>[p Ivan W. Smith, Chairman a
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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MEMORANDUM AND ORDER ON SHOLLY'S MOTION OF MARCH 3, 1980 TO COMPEL LICENSEE RESPONSE TO INTERROGATORIES Mr. Sho11y's March 3, 1980 Motion to compel Licensee Response to Interrogatories covers Sholly interrogatories08-019 and 08-024.
On March 24, 1980 the chairman telephoned Mr. Sholly to request that he report whether the licensee's response to Sholly interrogatory 08-006 also satisfied his expectation with respect to interrogatory 08-019.
By prearrangement with Mr. Sholly (in the event his report in writing was not timely received), the board's secretary on March 27 received the following telephoned report from him:
Intervenor Steven C. Sholly hereby advises the Board that licensee's response to interrogatory 08-006 is responsive to interrogatory 08-019 and therefore requests the Board to remove from con-sideration that portion of the Motion to Compel the licensee to answer interrogatory 08-019.
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2 This intervenor was contacted by the Chairman regarding this matter and this response is a result of that conversation.
The Board and other parties are hereby notified that an attachment to this intervenor's second Motion to Compel was inadvertently deleted when the motion was filed.
The attachment consisted of the original interrogatories which were the subject of the Motion to Compel.
The Chairman-advised this intervenor that the Board could pro-ceed to rule on the motion without receipt of the attachment.
Therefore the attachment will not be filed.
Mr. Sholly's interrogatory 08-024 to licensee states:
Specify any and all assumptions upon which the TMI Emergency Plan is based.
Discuss each such assumption and explain why it is appropriate and what it's basis is in fact.
The board can envision a virtually endless series of major or minor assumptions upon which any complex plan is based.
They could be studied assumptions or those automatically assumed (e.g.,
cars will start), implicit or express, direct or by incorporation.
The interrogatory is too broad.
Mr. Sholly's reference to the Commonwealth's response reporting evacuation times is inapposite.
That response was in reply to a request for specific assumptions.
We decline to enforce Mr. Sholly's interrogatory 08-024 THE ATOMIC SAFETY AND LICENSING BOARD By Ivan W. Smith, Chairman Bethesda, Maryland April 2, 1980
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