ML19326D797
| ML19326D797 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/01/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Environmental Coalition on Nuclear Power |
| Shared Package | |
| ML19326D782 | List: |
| References | |
| NUDOCS 8007030304 | |
| Download: ML19326D797 (7) | |
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NRC 7/1/80 r 'S
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of METROPOLITAN EDISON COMPANY.
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(Three Mile Island, Unit 1)
- h SECOND SET OF NRC STAFF INTERR0GATORIES OF ENVIRONMENTAL C0ALITION ON NUCLEAR POWER Pursuant to 10 C.F.R. 5 2.740b, the following interrogatories are directed to Environniental Coalition on Nuclear Power.
Each interrogatory is to be answered separately and fully in writing under oath or affirmation by individuals having personal knowledge of the answers. The Licensir,; Board in this proceeding has directed that all responses to: interrogatories must be in the hands of the discovering party 35 days after the issuance of the SER(July 21, 1980).
(The Memorandum and Order on Prehearing Conference of May 13,1980 (May 22,1980), at 7.)
. All parties are reminded that 6 2.740(e) of the Commission's regulations requires parties to amend their responses when they are no longer true.
Thus, intervenors who were not able to answer the general interrogstories submitted in the 'First Set of NRC Staff Interrogatories to Intervenors" dated December 27, 1979 or the interrogatories submitted in this pleading are obligated to respond to the interrogatories upon receipt of the requested infonnation.
8007030304
All of the specific interrogatories attached refer to information contained in the Staff's "TMI-1 Restart Evaluation of lice.asee's Compliance with the Short-and Long-Term Items of Section II of HRC Order dated August 9,1979" (SER) which was served on all parties to this proceeding on June 16, 1980.
Page nunbers in the interrogatories refer to the SER.
The general interroga-tories inquire into how the parties intend to use documents, including the SER, in their presentations of evidence.
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Respectfully submitted, t
Lucinda low Swartz Counsel for NRC Staff
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Dated at Bethesda, Maryland this 1st day of July,1980.
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-ECNP GEftERAL INTERROGATORIES 1.
Identify by author, title, date of publication and publisher, all books, documents and papers you intend at this time to employ or rely upon in presenting your direct case on:
a.
Contentions 1(a),(c),(d),(e) b.
Contention 2 c.
Contention 4 2.
Identify by author, title, date of publication, and publisher all books, documents, or papers that you intend at this time to employ or i
rely upon in conducting your cross-e.yamination of prospective NRC witnesses testifying in connection with; Contention 1(a),(c),(d),(e) a.
b.
Contention 2 c.
Contention 4 3.
If the representations made in:
Co7tention 1(a), (c), (d), (e) a.
b.
Contention 2 c.
Contention 4 are based in whole or in part on any documents prepared by the NRC Staff or the licensee which you contend are deficient, specify which documents (and the particular portions) you regard as deficient and explain why they are deficient.
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g SPECIFIC INTERROGATORIES Contention 2 On pages C3-1 through C3-5 of the SER,-the Staff evaluates the licensee's emergency plan. After reviewing this evaluation, please answer the fellowing questions:
2-1 Do you still contend that the licensee's emergency plan is inconsistent with those prepared by the state and local governments? If so, describe specifically each of the inconsistencies which you believe render the
-licensee's plan unacceptable.
Identify the documents which support your position.
(Refertopa0cC3-2).
2-2 Do you still believe that the licensee's offsite monitoring as described in the plan and evaluated in the SER is inadequate? If so, explain in detail the reasons for your belief and identify the documents which support your position.
(Refer to pages C3-2 and C3-3).
'2-3 Do you believe that the Staff's evaluation of the licensee's emergency plan is inadequate in any way? If so, describe in detail each' of those inadequacies and identify the documents which support your position.
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,o NRC 7/1/80 UNITED STATES OF AMERICA 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 ET AL.
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(Three Mile Island, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of:
SECOND SET OF NRC STAFF INTERR0GATORIES OF CHESAPEAKE ENERGY ALLIANCE SECOND SET OF NRC STAFF INTERROGATORIES OF ENVIRONMENTAL C0ALITION ON NUCLEAR POWER SECOND SET OF NRC STAFF INTERR0GATORIES OF NEWBERRY TOWNSHIP SECOND SET OF NRC STAFF INTERROGATORIES OF ANTI-NUCLEAR GROUP REPRESENTING YORK
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SECOND SET OF NRC STAFF INTERR0G_ATORIES OF THREE MILE ISLAND ALERT, INC.
SECOND SET OF NRC STAFF INTERR0GATORIES OF STEVEN C. SH0LLY SECOND SET OF NRC STAFF INTERR0GATORIES OF ttARVIN I. LEWIS SECOND SET OF NRC STAFF INTERROGATORIES OF MARJORIE M. AAMODT SECOND SET OF NRC STAFF INTERROGATORIES OF UNION OF CONCERNED SCIENTISTS in the above-captioned proceeding, have been served on those named on the attached service list, by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Conniission's internal mail system, this 1st day of July,1980.
M Lucinda low Swartz Counsel for NRC Staff
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UNITED STATES OF A': ERICA fiUCLEAR REGULATORY C0:i41SS10N BEFORE T11E ATOMIC SAFETY AND LICENSING BOARD _
In the Matter of METROPOLITAN EDIS0N COMPANY,
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(Three Mile Ir. land, Unit 1) h>
SERVICE LIST
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- Ivan W. Smith, Esq.
Mr. Steven C. Sholly i
Atomic Safety & Licensing Board Panel 304._ South Market Street U.S. Muclear Regulatory Commission Mechanicsburg, Pennsylvania 17055
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Washington, D.
C.
20555 i
Mr., Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection 881 W. Outer Drive Dept. of Environmental Resources Oak Ridge, Tennessee 37830 P.O. Box 2063 Harrisburg, Pennsylvania 17120 Dr. Linda W. Little 5000 Hermit' age Drive Mr. Marvin I. Lewis Raleigh, North Carolina 27612 6504 Bradford Terrace George F. Trowbridge, Esq.
Philadelphia, Pennsylvania 19149 Shaw: ?ittman, Potts & Trowbridge Metropolitan Edison Company 1800 a Street, N.N.
Attn: J.G. Herbein, Vice President Washington, D. C.
20006 P.O. Box S42 Reading, Pennsylvania 19603 L'arin W. Carter, Esq.
505 Executive House Ms. Jane Lee P.O. Box 2357 R.D. 3i Box 3521 Harrisburg, Pennsylvania 17120 Etters, Pennsylvania 17319 Honorable Mark Cohen Walter W. Cohen, Consumar Advocate 512 0-3 Main Capital Building Department of Justice Harrisburg, Pennsylvania 17120 Strawberry Square,14th Floor Harrisburg, Pennsylvania 17127
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, - - John Levin Esq.
Pennsylvania Public Utilities Conrn.
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Box 3265 Harrisburg, Pennsylvania 17120 Jordan D. Cunningham, Esq.
Allen R. Carter, Chairman Fox, Farr and Cunningham Joint Legislative Conmittee on Energy 2320 North 2nd Street Post Office Box 142 Suite 513 Harrisburg, Pennsylvania 17110 Senate Gressette Building Columbia, South Crrolina 29202 Theodore A. Adler, Esq.
e WID0FF REAGER SELK0WITZ & ADLER Post Office Box 1547
- Atomic Safety and Licensing Appeal Board Harrisburg, Pennsylvania 17105 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Ms. Ellyn R. Weiss Sheldon, Harmon, Roisman & Weiss o Atomic Safety and Licensing' Board Panel 1725 I Street, N.W.
U.S. Nuclear Reg'ilatory Commission Suite 506 Washington, D. C.
70555 Washington, D. C.
20006 o Secretary Ms. Karen Sheldon U.S. Nuclear Regulatory Commission Sheldon, Harmon, Roisman & Weiss ATIN:
Chief, Docketing & Service Br.
1725 I Street, N.W.
Washington, D.C.
20555 Suite 506 Robert Q. Pollard Washington, D. C.
20006 609 Montpelier Street t
Baltimore, Maryland 21218 Ms. Marjorie M. Aamodt R.D. #5 Coatesville, Pennsylvania 19320 Chauncey Kepford
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Judith H. Johnsrud Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania
- 16801 Ms. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant Postponement 2610 Grendon Drive Wilmington, Delaware 19808 Holly S. Keck Anti-Nuclear Group Representing York 245 W. Philadelphia Street' York, Pennsylvania 17404
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