ML19323D542
| ML19323D542 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/14/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Chesapeake Energy Alliance |
| References | |
| NUDOCS 8005210654 | |
| Download: ML19323D542 (13) | |
Text
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LIC 4/14/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S RESPONSE TO CEA INTERROGATORIES PERTAINING TO PSYCHOLOGICAL DISTRESS (CONTENTION NO. 4)
INTERROGATORY NO. 4-1 Summarize and explain Licensee's position on this contention.
Identify all documents relied on in reaching that position.
RESPONSE
Licensee objects to this interrogatory for the reasons set forth in its objections to the first interrogatory for each contention contained in CEA's First Set of Interrogatories to Licensee, to which Licensee filed its objections on March 14, 1980.
INTERROGATORY NO. 4-2 Identify those aspects of the contention that Licensee considers to be matters of controversy.
For each of those aspects, summarize briefly the opposing positions on the controversy as it is perceived by Licensee.
Iden-tify and summarize all documents in support of either position.
3 80052 l a (F5?9'
)
RESPONSE
Licensee objects to this interrogatory for the reasons set forth in its objections to the second interrogatory for each contention contained in CEA's First Set of Interrogatories to Licensee, to which Licensee filed its objections on March 14, 1980.
INTERROGATORY NO. 4-3 Identify and briefly summarize any and all documents known to Licensee that would tend to provide evidence and/or support for the contention.
RESPONSE
Licensee objects to this interrogatory for the reasons set forth in its objections to the third interrogatory for each contention contained in CEA's First Set of Interrogatories to Licensee, to which Licensee filed its objections on March 14, 1980.
INTERROGATORY NO. 4-4 Identify any and all persons known to Licensee who have knowledge or expertise that would tend to support this contention.
For each person, provide name, address, telephone number, and qualifications, and a summary of the nature of the evidence expertise that person would be able to offer.
RESPONSE
This interrogatory is similar to Interrogatory No. 4-3 except that it calls upon Licensee to identify persons rather than documents whose expertise or knowledge would tend to l
l support CEA's contention.
Licensee objects to this interroga-tory for the same reasons it objects to Interrogatory No. 4-3.
INTERROGATORY NO. 4-5 Identify any and all experts that Licensee intends to have testify on the contention; state the qualifications of each expert; and present a summary of the testimony that each expert is expected to provide.
RESPONSE
Witnesses have not yet been selected by Licensee and testimony stating Licensee's position has not been drafted, reviewed or finalized.
INTERROGATORY NO. 4-6 Identify any and all members of Licensee who dissent from the overall Licensee position on this contention, and for each such person, provide a summary of their dissenting position on the contention.
RESPONSE
See Licensee's response to CEA Interrogatory No.
4-5.
INTERROGATORY NO. 4-7 Identify the critical or central parameters of this contention as it is perceived and understood by Licensee, and briefly evaluate Licensee's evaluation of the importance i
of each such parameter.
RESPONSE
i Licensee objections to this interrogatory for the reasons set'forth in it; objections to the sixth interrogatory for each
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contention contained in CEA's First Set of Interrogatories to Licensee, to which Licensee filed its objections on March 14, 1980.
INTERROGATORY NO. 4-8 Identify any and all documents that have been prepared or commissioned by or for Licnesee to investigate the cred-ibility, as perceived by the public within the general vicinity (whether that be a ten mile radius, surrounding townships or counties, or other boundary) of TMI, of Licensee, or agents of Licensee, whether that credibility be of a general nature, or specifically in respect to the accuracy of reported offsite radiation levels.
Identify the authors of each such document, and their qualifications.
RESPONSE
No documents have been prepared or commissioned to date by or for Licensee to investigate the credibility, as perceived by the public within the general vicinity of TMI, of Licensee or its agents.
INTERROGATORY NO. 4-9 Identify any and all reports known to Licensee, including reports in newspapers and media in the TMI area, that show evidence that there is, or has been since 3/28/79, any sub-stantial lack of public trust in the credibility or validi-ty of reports on the TMI-2 accident by Licensee, whether those reports do or do not specifically involve reports on the levels of offsite radiation.
RESPONSE
The Report of the President's Commission on The Accident at Three Mile Island (the Kemeny Report), dated October, 1979, j
and the NRC Special Inquiry Group Report to the Commissioners and to the Public on Three Mile Island (the Rogovin Report),
i 1
released in January, 1980, discuss the issue of public trust in the credibility or validity of reports on the TMI-2 acci-dent by Licensee.
With regard to CEA's request for reports in newspapers and media in the TMI area dealing with this subject, Licensee has accumulated a voluminous amount of newspaper clippings on the TMI-2 accident, some of which undoubtedly bear on the question of public trust in the credibility or validity of Licensee's reports on the accident.
Licensee is willing to put all of these news clippings in Licensee's Discovery Reading Room for a specific 10 day period, upon CEA's request.
CEA can as easily go through this material as Licensee and must assume the responsibility for selecting tems which in its view bear upon its contention.
INTERROGATORY NO. 4-9 (sic)
Identify and describe any measures that are known to Licensee to have been taken to address any lack of public credibility in Licensee's reports, whether they involve specifically offsite radiation levels or not.
Identify the persons or agencies that have taken those measures, and also describe any observable consequences of those measures.
RESPONSE
Licensee has taken and is currently taking numerous measures to address public credibility in Licensee's reports.
Licensee's management has consciously adopte. a policy of e
openness to the public on past and present events at TMI in order
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to improve its credibility and, generally, foster public trust in Licensee's nuclear facilities at TMI.
This policy manifests itself in many ways, including continuous notificatior.s to the public, through local officials, of events at the TMI site of potential public interest; briefing sessions through various Federal, state and local organizations on the past and current status of TMI, at which question and answer sessions are en-couraged by Licensee; press releases on events of public inter-est and, generally, accessibility of Licensee's management to the media; solicitation of local organizations and groups to take tours of TMI; and attendance and accessibility at public meetings in order to understand the issues of interest to the public and to answer questions about TMI.
Licensee's management is also interested in supplying the community with accurate information about the TMI-2 accident, pnd the status and significance of subsequent events at TMI.
Licensee encourages local groups to request information on TMI, and on nuclear power generally, and is interested in providing as much of this information to the public as possible.
Licensee l
hopes that more requests for information, and self-education by the public and various groups within the public, will be forthcoming. f
INTERROGATORY NO. 4-10 Describe any and all steps that may have been taken to assemble a truly independent (both of Licensee and of NRC) means of measuring and reporting offsite radia-tion levels, including in that description the steps that have been taken to establish that such an indepen-dent means of monitoring and reporting offsite radiation levels would have the confidence of the public in the TMI area.
RESPONSE
Licensee has purchased a real time radiation monitoring system for placement offsite.
These monitors will permit direct offsite readings by public officials.
In addition, a program is currently under advisement by Licensee that will place data acquisition terminals at locations designated by public officials that will permit remote interrogations of tne radiation sensors.
INTERROGATORY NO. 4-11 Insofar as the public credibility of Licensee is related to the public's perception (in the TMI area) of the NRC itself (as the agency responsible for regulating Licensee),
identify any and all evidence that shows or tends to show a lack of public confidence in the acticns and/or statements of the NRC.
Describe the nature of such evidence, and the persons reporting such evidence.
RESPONSE
Licensee objects to CEA's request for any and all evidence that shows or tends to show a lack of public confidence in the actions and/or statements of NRC.
Licensee is under no obliga-l tion and will not conduct CEA's legal investigations for it.
Further, the credibility of the NRC is not within the scope of CEA's psychological distress contention. _
C INTERROGATORY NO. 4-12 Identify and describe any and all evidence, reports, and documents known to Licensee that pertain specifically to the public's lack of credibility in Licensee's reports of offsite radiation levels, to the specific components and bases for the public's lack of confidence in Licensee's reports of offsite radiation levels, and to the remedies that are perceived by the public to be necessary for the public to have full confidence in reports of offsite radi-ation levels.
Describe the nature of all such evidence, and the author (s) of all reports and documents cited.
RESPONSE
For the reason articulated in Licensee's objection to CEA Interrogatory No. 4-11, Licensee will not conduct CEA's legal search for evidence.
However, Licensee is not aware of any reports or documents pertaining specifically to the public's lack of credibility in Licensee's reports of offsite radiation levels, to the specific components and bases for the public's lack of confidence in Licensee's reports of offsite radiation levels, and to the remedies that are perceived by the public to be necessary for the public to have full confidence in reports of offsite radiation levels.
INTERROGATORY NO. 4-13 Describe any and all action taken or planned by Licensee to address the lack of public confidence in Licensee's reports of of fsite radiation levels.
Describe the time-table for such action, and identify the person (s) who will be responsible for implementing the action. -
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RESPONSE
j See Licensee's response to CEA Interrogatory No. 4-10.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE i
By M
M
_/
yo'rge/F. Trowbridge
/
D a t r '. :
April 14, 1980.
i i -.-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
j 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 Response To CEA Interrogatories Pertaining To Psychological Distress (Con-tention No. 4)" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 14th day of April, 1980.
M N
a Geo[ge F. Trowbridge[
Dated:
April 14, 1980.
i 1
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LNITED 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 Ivan W. Smith, Esquim John A. Iavin, Escuire ChairIran Assistant Counsel Atanic Safety and Iicensing Pennsylvania Public UH14ty Carm'n Board Panel Post Office Box 3265 U.S. Nuclear Pegulatory Cemission Ram 4 +urg, Pennsylvania 17120 Washington, D.C.
20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General At:ric Safety and Licensing 505 Executive House Board Panel Post Office Bax 2357 881 West Outer Drive Harrisburg, Paansylvania 17120 Oak Riche, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chaiman, Dauphin County Boarti Atomic Safety and Licensing of Ccrnrissiones Board Panel Dauphin County Cotrthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 EarristL_9g, Pennsylvania 17101 James R. 'Iburtellotte, Esquim Walter W. Cohen, Escp.1Lm Office of the E:xecutive Iagal Director Constraer Advocate U. S. Nelaar Pagulatory Cct: mission Office of Constraer Advoc: ate Washingten, D.C.
20555 14th Floor, Strawberry Squam Harrisburg, Pennsylvarda 17127 Docketing and Service Section Office of the' Secretary l
U. S. Nuclear RegulatcLn.f Cc:rmission Washington, D.C.
20555 m
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Karin P. Sheldon, Esquire Jordan D. CLWham, F. squire Attorney for People Agairst Nuclear Atto:=ey for Newberry Township Energy T.M.I. Steerirs Cc:mtittee Sheldon, F L m & Weiss
?.320 North Second Street EL h.%, Pennsylvania 17110 172S Eye Street, N.W., Suite 506 Washington, D.C.
20006
'Lheodore A. Adler, Esquire Bcbert Q. Pollard Widoff Peager Selk=witz & Adler c.esapeake Energy Alliance Post Office Box 1547 Fa %, Pennsylvania 17105 609 Mcntpa'ier Street Baltircre, Maryland 21218 F11yn R. Weiss, Esquire Attorney for the Unica of Concerned Clauncey Repford Judith H. Jahrsrud Scientists Envia.use_ntal Coalition on Nelaw Sheldon, Warrrn & Waies Power 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006 433 Crlando Avenue State College, Pennsylvarda 16801 Steven C. Sholly Marvin I. Iawis 304 South Market Street Mechapi M urg, Pennsylvania 17055 6504 Bradford Terrace Philadalphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aa:nodt Eclly S. Keck R. D. 5 legislation On4mn Coatesville, Pennsylvania 19320 Anti-Nuclear Grous Pepresenting York 245 West Philnaalphia Street York, Pennsylvania 17404 b
SHAw, PITTM AN, PoTTs & TROWB RIDG E 18 0 0 M STR E CT, N. W.
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PMcLi p J. M ARvCY CARLETON S. JON ES ROSERT M. GORDON THOM AS A. SA ATER JCANN E A. CALDERON JAM E S M. 5 URGER SARSARA J.MORGEN' S MCLOON J. WCISEL SONNIE S. GOTTLsCS JOM N A. Mc C.ULLOUQM ALFR E.D.. M. POSTELL Acril 14 1980 J. RATRiC M MCMET SETH MOOoAS C. Mc CA F F'A" i
JAMES TMOMAS LENHART SMCILA ERTY STEVEN L.MELTZER O C LIS SA A. RIOG WAY DEAN D. AULIC E M EN N ETH J. M AUTM AN JOMN ENGEL QAVIO LAWRCNCE MILLER
'mOf ADeseTTED ise O C.
Dr. Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218 Re:
Three Mile Island, Unit 1 Docket No. 50-289 (Restart)
Dear Dr. Pollard:
Enclosed is Licensee's response to CEA Interrogatories to Licensee pertaining to psychological distress filed March 26, 1980.
A signed affadavit for this response is not enclosed but will be forwarded soon.
Si-rely v s,
A eo e F.
Trowbridge 1
l Enclosure cc:
Service List i
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