ML19309G146

Interrogatories Directed to Nrc.Requests NRC Position Re Intervenor Contentions 1 & 2 & Psychological Distress Among People Living within Five Miles of Reactor.Certificate of Svc Encl

ML19309G146
Person / Time
Site:	Three Mile Island
Issue date:	03/31/1980
From:	Jordan W, Sheldon K PEOPLE AGAINST NUCLEAR ENERGY, SHELDON, HARMON & WEISS
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8005050034
Download: ML19309G146 (10)

Text

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UNITED STATES OF AMERICA >

NUCLEAR REGULATORY COMMISSION /

DOCF.ETED BEFORE THE ATOMIC SAFETY AND LICENSING BOAR. WNRC

-- MAR 3 g g  ::

.e In the Matter of )

)

b Docket No. 50-289 13

$hh ga y METROPOLITAN EDISON COMPANY ) (Restart) q) 03

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(Three Mile Island Nuclear )

Station, Unit, No. 1) )

People Against Nuclear Energy Interrogatories to Nuclear Regulatory Commission Staff Pursuant to 10 CFR S2.740, Intervenor People Against Nuclear Energy (PANE) requests that these interrogatories be answered fully, in writing, and under oath by any employees or representatives of the Nuclear Regulatory Commission (Staff) who have personal knowledge of the facts or issues in question. The answer to each interrogatory should contain l 1

the name and identification of each person supplying or contributing to the answer, whether or not he or she has verified the answer. The answer should also explain the role of each individual in preparing the answer.

Definitions and Instructions Unless otherwise indicated, the following definitions shall apply to these interrogatories:

1. Staff shall include not only the Nuclear Regulatory Commission Staff itself, but also all agents, employees, attorneys, investigators, and all other persons directly or I

l indirectly subject to the control of the Nuclear Regulatory 1

Commission Staff.

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2. The words " person" or " persons" shall mean, without limitation, all entities, including all predecessors in interest, individuals, associations, companies, partnerships, joint ventures, corporations, subsidiaries, departments, bureaus, public agencies, and boards.

3. " Documents" shall mean all written or recorded material of any kind or character known to the Staff or in the Staff's possession, custody, or control, including, but not limited to letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records of notations of telephone or personal conversations or con-ferences, inter-office communications, microfilm, bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings and worksheets.

4. When used with respect to a document, " identify" l

means, without limitation, to state its date, the type of document (e.g., letter, memorandum, telegram, chart, photograph, sound reproduction, etc.), the author and addressee, the

, present location and the custodian, and a description of its 1

comments.

i 5. When used with respect to a person, " identify" means, without limitation, to state his or her name, address, occupation, and professional qualifications.

6. The terms "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of these interrogatories any information that might otherwise be construed to be outside their scope.

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7. If any of the information contained in the answers to any of these interrogatories is not within the personal knowledge of the person signing the response to that interrogatory, so state and identify each person, document, and communication on which he relies for the information contained in answers not based solely on his personal knowledge.

8. If the Staff cannot answer any portion of the following interrogatories in full, after exercising due diligence to sebure the information to do so, so state and answer to the extent possible, specifying the inability to answer the remainder and stating when the Staff expects to be able to answer the unanswered pornions.

9. These interrogatories are continuing interrogatories and require supplemental answers if the Staff obtains further information between the time the answers are served and the time of an initial decision in the proceeding.

Interrogatories

1. Please state Staff's position with respect to each of PANE's Contentions 1 and 2.

2. With respect to each of PANE's Contentions 1 and 2, please

a. Identify each person whom Licensee expects to call as an expert witness concerning the contention;

b. State the subject matter on which the expert witness is expected to testify;

c. State the substance of the facts and opinions to which the expert witness is expected to testify, and summarize the grounds for each opinion; i

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d. Identify all documents relied upon or examined by the expert witness in answering (c) above;

e. Identify all documents not identified in response to (d) above which the expert witness expects to put into evidence or to rely upon in support of his or her testimony in this proceeding.

3. Please identify all other persons whom the Staff expects to call as witnesses concerning the issues raised by PANE's Contentions 1 and 2.

a. Please answer interrogatory 2 (a)-(e) with respect to each potential witness identified in l response to this interrogatory.

4. With respect to all persons identified by the Staff ..

in response to interrogatories 2 and 3, please

a. Provide a complete bibliography of all articles, books, or scholarly works published or presented by each person, including a brief description of the substance of each.

b. Identify and provide appropriate citations for all proceedings in which the person has previously appeared as a witness.

5. Please identify all persons with whom the Staff has consulted or expects to consult concerning each of PANE's Contentions 1 and 2 and who has knowledge of facts relating to either of those contentions.

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a. For each person who has been consulted, state l

l when he or she was consulted and summarize the l

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substance of any facts or opinions communicated by such person to the Staff concerning the subject matter of PANE Contentions 1 and 2.

b. Please identify all documents or studies referred to by persons identified in response to this interrogatory.

6. Identify all documents that the Staff expects to introduce into evidence or use for impeachment or other cross-examination purposes in this proceeding, other than those identified in response to other interrogatories.

7. Does the Staff deny that the accident at Three Mile Island Unit 2 caused any psychological or mental distress among people living near the reactor, and in particular among those living within five miles of the reactor? What is the basis for this answer?

8. If the Staff does not deny that the accident caused some psychological or mental distress in the surrounding population,

1. Please explain what sort of stress Staff believes was caused by the accident, whether that stress continues to exist, and what impact the reopening of TMI Unit 1 would have on persons suffering from that stress.

2. Please explain what actions' Staff believes are necessary to alleviate the mental stress caused by the accident.

3. Please explain what accions Staff intends to take to alleviate the mental stress caused by i

. the accident.

9. Is the Staff's position that TMI Unit 1 should be allowed to reopen regardless of the severity of the psychological or mental stress that might be caused by the reopening?

10. Please identify all residents or former residents of the area within 20 miles of TMI and all other persons who were within 20 miles of TMI during the two weeks after the accident whom the Staff has contacted since the accident or about Caom the Staff has obtained information since the accident and whose psychological or mental condition the Staff has considered, evaluated, or commented upon in any way, with or without the knowledge of the person involved. Please identify and provide copies of all documents that were referred to or relied upon by the Staff in answering this interrogatory or that are otherwise relevant to this interrogatory.

11. Please identify all physicians, social workers, therapists, nurses, and other health professionals, both in the vicinity of TMI and elsewhere, whom the Staff has contacted concerning the issue of possible psychological or mental stress caused by the accident at TMI Unit 2 or that might be caused by reopening TMI Unit 1.

a. Please state when these contacts were made and summarize the substance of any facts or opinions communicated by these persons to the Staff.

l b. Please identify and provide copies of all l

documents referred to by these persons or provided to the Staff by these persons.

e

12. Please identify and provide copies of all documents '

known to the Staff and sent to, received from, or otherwise relating to the following persons:

Dr. James Titchener University of Cincinnati Dr. E.L. Quarantelli Ohio State University Dr. Cal Fredericks National Institute of Mental Health Dr. Robert Jay Lifton Yale University Dr. Kai Ericson Yale University Dr. Evelyn Bromet University of Pittsburgh Dr. Martin Smith Long Island University Dr. Bruce P. Dohrenwend Columbia University Dr. Barbara Snell Dohrenwend Columbia University Dr. Stanislav V. Kasl Yale University Dr. George J. Warheit University of Florida Raymond L. Goldstein Columbia University

13. Please identify and provide copies of all dccuments, prepared by or known to the Staff which evaluate, contaia Staff's reaction to, or otherwise relate to or reflect the concluslon of the President's Commission on the Accident at Three Mile Island (the Kemeny Commission) that severe mental stress was the most serious health effect of the accident.

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14. Please identify all real estate agents, brokers, and others knowledgeable about real estate transactions and prices in the vicinity of TMI, and all memliers of the business community, local government leaders, local government employees (including anyone employed by or connected with the school systems) , and community leaders whcm the Staff has contactee or conruited concerning the issues raised by PANE's-Contention 2.

a. Please identify and provide copies of all documents recording, reflecting, or otherwise related to the contacts with persons identified in response to this interrogatory.

15. Does the Staff know of anyone who has moved any distance,'away from the reactor as a result of the accident?

Please identify all such persons.

16. Does the Staff know of anyone who has failed or refused to take up residence or open any type of business within a 20 mile radius of TMI as a result of the accident?

Please identify all such persons.

17. Please identify all documents of which the Staff is aware that relate to the issues raised by PANE's Contentions 1 and 2 and have not previously been identified in response to these interrogatories.

18. Please identify all persons of whom the Staff is aware who have any knowledge of the facts or issues raised by PANE's Contentions 1 and 2 and who have not previously l

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UNITED STATES OF AMERICA p */ g NUCLEAR REGULATORY COMMISSION 00 D b BEFORE THE ATOMIC SAFETY AND LICENSING BOARD pc 2h MAR 311980 [s

) g Uhchth8M s&WC8 p In the Matter of ) Stad I  % G METROPOLITAN EDISON ) con COMPANY, et al.,

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) Docket No. 50-289

) (Restart)

(Three Mile Island )

Nuclear Station, Unit )

No. 1) )

)

CERTIFICATE OF SERVICE I hereby cerdfy that a copy of " People Against Nuclear Energy Interrogatories tc NIC Staff" was mailed first class postage pre-paid this 31st day of March, 1980 to the following parties:

• Secretary of the Commission ATTN: Chief, Docketing and Service Section ,

U.S. Nuclear Regulatory Commission  !

Washington, D.C. 20555 Ivan W. Smith, Esquire j Atomic Safety & Licensing Board Panel U.S. Nuclear stegulatory Commission r " 91 Washington, D.C. 20555 .

OCKETED \

Dr. Walter H. Jordan /- ucna T 881 W. Outer Drive 'I Oak Ridge, Tennessee 37830 ' " ' 'O > d D' Officeof ' ecretary 2 Dr. Linda W. Little D0cht' & crdes ,

5000 Hermitage Drive ##Ch Raleiegh, North Carolina 27612 b O (b -4 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge l 1800 "M" Street, N.W.

Washington, D.C. 20006 l

• James Tourtellotte, Esquire l Office of the Executive Legal Director U.S. Nuclear Regulatory Commission l Washington, D.C. 20555

• Hand-delivered 8

j dliam S'. Jordan, III l

1

been identified in response to these interrogatories.

Respectfully submitted, hfA - I) 2 William S. Jordan, III Lte np Karin P. Sheldon Sheldon, Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 (202) 833-9070 Counsel for PANE DATE: March 31, 1980 l

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