ML19323B111

First Set of Interrogatories Directed to State of PA Re Emergency Plan & Emergency Workers.Certificate of Svc Encl

ML19323B111
Person / Time
Site:	Three Mile Island
Issue date:	03/26/1980
From:	Aamodt N AFFILIATION NOT ASSIGNED
To:	PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML19323B100	List: ML19323B099 ML19323B104 ML19323B111
References
NUDOCS 8005090276
Download: ML19323B111 (4)

Text

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?. g March 26,1980 8005090$7h O $ ga 2 mo

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d the seedsrf IO United States of America

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Nuclear Regulatory Commission A

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Before the Atomic Safety and Iicensing Board In the hatter of Metropolitan Edison Company, Three Mile Island Nuclear Station, Unit 1 Docket 5C-289 FOLLOWUP --

AAMODT INTERROGATORIES OF CQ&OSEALTH OF FENNLYLVANIA (FIR 5T 2.ET)

Responses of David S. Ingraham Interrog. 12-b "if not, why not" was not answered.

Interrog.17 a-e please answer completely, particularly with respect to " planned" provisions.

Interrog.19 a-c please answer all questions completely, particularly.

b and c which serve as a basis for judging practicality of livectock evacuation.

Responses of Wallace C. Evans Interrog. 6,7,8,9,10, 16, 16c and d . All responses impermissibily evasive. The Commonwealth lacks neither the resources nor the in-tellect to provide helpful responses. Its commitment to a viable agricultural community would certainly be consistent with an aware-ness of the impact the requested information can have on forming a judgement concerning the need and appropriateness of an emergency plan which would provide for evacuation and/or appropriate care of livestock and would minimize hazard to the health and safety of farm operators in the event of a severe accident.

i Responses of leroy-C; Corbin, Jr. ~_ .-

Interog. 2 a and b response lacks precision. Please provide map.

showing actual locations and data generated from 1974 to date, as requested.

Responses of G. W . Fouse S

l Interrog.1 and 3 rssponso lacks complotensss. Pleaso provido all data gathered 1974 to present. Also (3a) provide basis for

l l sample selection and appropriate maps showing sampling locations. l l

Responses of L;argaret A. Reilly  !

Interrog. 15A'- how! Please delineate those considerations which would cause farmers to be considered " emergency workers" which would  !

also apply to office workers , home owners and bank managers. '

Interrog.1 b and e - Please provide data 1974 to present.

Interrog. 3 - Please provide information relative to basis for the testing that is done and data as requested.

Responses of Rob 6rt C. Furrer

'Interrog.1 h - Please answer in more detail.

Interrog. 15B - Flease refer this question to the Secretary of Agriculture.

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l Respectfully submi1;ted I

/ $lHdo!. c&cw6 Noman O. Aamodt l

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Merch 27, 1980 -

United btates of America D Nuclear Regulatory Commission Before the Atomic Eafety and Licensing Board In the Matter of Metropolitan Edison Company, Thr.ee Mile Island Nuclear Station, Unit 1, Docket 5C-289 CERTIFICATE OF EERVICE I hereby certify that copies of the following:

REQUEST OF BOARD FOR EXTENSION OF TIME FOR AN40DT DEPOSITION OF COMMONWEALTH OF PENNSYLVANIA FOI.LOWUF -- AAMODT INTERROGATORIES OF COMMONWEALTH OF PENNSYLVANIA 1 I

(SECOND SET)

~ FOLLOWUP .-- AN40DT INTERROGATORIES OF COI7.ONWEALTH OF PENNSYLVANIA (FIRST SET) were served on those persons on the attached service list by deposit in the United States mail, postage prepaid, this 27th day of March, 198C. -

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Marjo le M. Aamo'dt Dated: March 2 1^ 9

t occ< m s USNRO 4

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APR 21980 > -

9' Officaof 7g

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gELATED CORRESNM '

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

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1)

SERVICE LIST George F. Trowb. ridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W. )

Washington, D.C. . 20036 7 _.,__

Ivan'W. Smith, Esquire ,

g Chairman g Atomic Safety and Licensing

1. D Board Panel DOCKETED U.S. Nuclear Regulatory I i

9 Commission USNRG b 20555 Washington, D.C. ,

t-[ APR 2$80> [-

? Oh Dr. Walter H. Jordan s

Atomic Safety and Licensing '

% Y Board Panel '

~ g, 881 West Guter Drive Oak Ridge, Tennessee 37830 Dr. Linda W. Little Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, North Carolina 27612 James A. Tourtellotte, Esquire  ;

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washfngton, D.C. 20555

.Karin W. Carter, Esquire .

Assistant Attorney Ceneral

, . 505 Executive Ecuse Post Office Bcx 2357 ,

Harrisburg, Pennsylvania 17120'.

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