ML19339C044
| ML19339C044 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/10/1980 |
| From: | Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Sholly S AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8011170231 | |
| Download: ML19339C044 (9) | |
Text
'
4",\\\\* I v)
Lic 11/10/80
,4cs 2
"hhs
%;? (c))
4. -.
e UNITED STATES OF AMERICA 5 g'eh 'e /
C.'
8
,y H
- A %.
$!!:*%>h O; NUCLEAR REGULATORY COMMISSION "c5*%
, y
-)};,
/ 's f., p. g \\ '-
"\\
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)
)
LICENSEE'S INTERRCGATORIES TO INTERVENOR STEVEN C. SHOLLY ON HIS CONTENTIONS 8 (III) (B)- (D)
These interrogatories are filed pursuant to 10 C.F.R.
S 2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation, and the Board's order at page 4500 of the October 31, 1980 i
hearing transcript authorizing such discovery.
t Interrocatory No. 1 With respect to your concerns in Contention 8 (III) (3) about the effectiveness of " phased, preplanned readiness and evacua-tion precedures", do you contend that there is anything unique or different about Cumberland County, or its emergency respense plan, that would render such procedures ineffective?
If so, identify the unique or different characteristics that you rely upen, and explain for each such characteristic the effect it would have on phased, preplanned readiness and evacuation cro-o3 cedures.
5 LO11170LM
'I
. Interrogatory No. 2 If the concept of phased, preplanned readiness and evacua-4 tion procedures was shown to be an effective part of the Stste Plan, or of the emergency response plan from one of the other four affected counties, would you still contend that such a concept was not appropriate for Cumberland County?
If so, ex-plain the basis for that view.
Interrogatorv No. 3 Do you contend that a greater percent of the Cumberland County population within the 10-mile EPZ would require mass care than would be true for non-Cumberland County residents?
If so, explain the basis of that conclusion.
Interrogatory No. 4 (a)
Identify all Cumberland County parks and recreation facilities within the 10-mile EPZ which are included in your Con-cention 8 (III) (C) (1).
(b)
Ideatify all cther Cumberland County parks and recrea-tion f acilities included in your Contention 3 (III) (C) (1), and for each list its distance from the TMI-l site.
(c) 'For each park and recreation facility identified in response to Interrogatories 4 (a) and 4(b), describe the special considerations which you contend require special attention dur-ing an evacuation.
9 tate the basis for ycur response, and indi-cate why you believe the Cumberland County Emergency Response Plan does not adequately handle this matter.
. Interregatory No. 5 (a)
Identify all Cumberland County public and private i
schools within the 10-mile EPZ which are included in your Con-
. tent on 8 (III) (C) (2).
i Ob)
Identify all _ other Cumberland County public and private schools included in your Contention 8 (III) (C) (2), and for each list its distance'from the TMI-l site.
j l
(c)
For each public and private school. identified in response to Interrogatories 5 (a) and 5 (b), dese. ribe the special considerations which you contend require spec.al attention dur-i l
ing an evacuation.
State the basis for your response, and indi-cate why you believe the'Ccaberland County Emergency-Response Plan does not adequately handle this matter.
Interrogatory No. 6 i
(a)
Identify all Cumberland County colleges within the 10-i i
mile EPZ which are included in your Contention 8 (III) (C) (3).
4 Ob)
Identify all.other Cumberland County colleges included 1
i j
in your Contention 8 (III) (C) (3), and for each list its distance from the TMI-l site.
(c)
For each college identified in response to Interroga-tories 6(a)_ and '6 (b), ~ describe the special considerations which you contend require special attention during an evacuation.
State the basis for your response, and indicate why you believe the Cumberland County Emergency Response Plan does not adequately handle this matter.
~(d).Do'you contend that, as a group, college-students t
. ~...
. require special attention during an evacuation?
If so, describe the special attention they need and state the basis for that view.
Interrocatorv Nc. 7 (a)
Identify all Cumberland County prisons and jails within the 10-mile EPZ which are included in your Contention 8 (III) (C) (4).
(b)
Identify all other Cumberland County prisons and jails included in your Contention 8 (III) (C) (4), and for each list its distance from the TMI-l site.
(c)
For each prison and jail identified in response to Interrogatories 7(a) and 7(b), describe the special considera-tions which you contend require special attention during an evacuation.
State the basis for your response, and indicate why you believe the Cunbcrland County Emergency Respense Plan i
does not adequately handle this matter.
Interrocatory No. 8 (a)
Identify all Cumberland County hospitals, nursing homes and rehabilitation centers within the 10-mile EPZ which are in-cluded in your Contention 8 (III) (C) (5).
(b)
Identify all other Cumberland County hospitals, nursing i
hcmes and rehabilitation centers included in your Contention 8 (III) (C) (5), and for each list its distance frem the TMI-1 site.
1 (c)
For each hospital, nursing home and rehabilitation I
center identified in response to Interrogatories 8(a) and 8(b),
t I
describe the special considerations which you centend require special attention during an evacuation.
State the basis for l-your response, and indicate why you believe the Cumberland i
. County Emergency Response Plan does not adequately handle this matter.
Interrogatory No. 9 I
(a)
Identify all Cumberland County f actories and shopping malls within the 10-mile EPZ which are included in your Conten-tion 8 (III) (C) (6).
(b)
Identify all other Cumberland County factories and and shopping malls included in your Contention 8 (III) (C) (6),
for each list its distance from the TMI-l site.
(c)
For each factory and shopping mall identified in response to Interrogatories 9 (a) and 9 (b), de;cribe the special considerations which you contend require special attention dur-ing an evacuation.
State the basis for your response, and indi-cate why you believe the Cumberland County Emergency Response Plan does not adequately handle this matter.
Interrogatory No. 10 (a)
Identify all "other similar concentrations of popula-tion" as that phrase is used in your Contention 8 (III) (C) (6), and for each list its distance from the TMI-l site.
i (b)
For each concentration of population so identified, describe the special considerations which you contend require special attention during an evacuaticn.
State the basis for your response, and indicate why you believe the Cumberland County Emergency Response Plan does not adequately handl2 this matter.
. Interrogatory No. 11 (a)
How far frem the TMI-l site are the residents of the New Cumberland area who are referred to in your Contention 8 (III) (D) ?
(b)
Ecw far from the TMI-l site are the residents of Mechanicsburg who are referred to in your Contention 8(III) (D) ?
(c)
State the basis on which you contend that "[i] t is not reasonable to expect residents of Mechanicsburg to evacuate to a location only 5-7 miles more distant from where they live wheh other county residents will evacuate to more distant loca-tions."
Identify all evidence that you intend to rely upon in proving such an allegation.
Respectfully submitted, SHAW, PITTMAN, PCTTS & TROWBRIDGE By:
e Robert E.
2ahler Dated:
Nove=her 10, 1980 I
Lic 11/10/80 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
)
(Res tart).
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Inter-rogatories to Iitervenor Steven C.
Shelly on his Contentions 8 (III) (B)-(D) ", were served upon those persons on the attached j
Service List by deposit in the United States mail, postage prepaid, this 10th day c f November, 1980.
AJ Robert E.
La31er Dated:
l'ovember 10, 1980
UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSICN BEFORE THE ATCMIC SAFETY AND LICENSING 3 CARD In the Matter of
)
)
METROPOLITAN EDISCN COMPANY
)
Docket Po. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
)
Station, Unit No. 1)
SERVICE LIST Ivan W. Smith, Esquire Jchn A. Ievin, Esquim Chai =an Assistant Cetr.sel Atanic Safety and Licensing Pennsylvania Pchlic Utility Camt'n Scard Panel Post Office Scx 3265 U.S. Nuclear Pegulatcry Ccrissicn Harisburg, Pennsylvania 17120 Washi.gt=n, D.C.
20555 Karin W. Carter, Esquire Dr. Walter H. Jcrdan Assistant Attcrney General Atanic Safety and Meensing 505 Executive Ecuse Scard Panel Post Office Bcx 2357 881 West Outer Drive Hanisburg, Perr.sylvania 17120 Cak Ridge, Tennessee 37830 Jchn E. Mir.nich Dr. Lird.a W. Little Omi=an, Dauphin County Beard Atanic Safety ard Licensi:x; of Cc:missicrars Beard Parel Dauphin County Ccurthouse 5000 He=itage Drive Frent ard Market St:.tets Paleigh, North Carolina 27612 Harisburg, Pennsylvania 17101 Jares R. Tourtellette, Esquire Walter W. Cchen, Es @
Cffice of the Executive Iagal Directr Ccnstner Mvecate U. S. Nuclear Pegulatory Carissicn Office of Censumer exx: ate Washirx; ten, D.C.
20555 14th Flocr, Stratury Square Harisburg, Pennsylverla 17127 Docketing ard Service Secticn Offim cf the Secretary U. S. Nuclear Pegulatcry Comtissian Washirgten, D.C.
20555
~,
\\
1 4
),
l Jordan D. Cunningham, 7 squire William S..Tordan, III, Esquim AttcIney for Ne% terry Tcwnship Attcrney fc;: Pecple ;cainst Nuclear T.M.I. Steeds Ccr.tnittee Energy 2320 Ncrth Second Street Har:ncn & Weiss HarriL%7, Pennsylvania 17110 1725 Eye Stmet, N.W., Suite 506 Washingten, D.C.
20006 Thecdcre A. Mler, Esquire Wideff Feager Selkcwitz & Mler Fabert Q. Pcilard Post Office Scx 1547 609 L ui.Alier Street
. Harrisburg, Pennsylvania 17105 Baltircre, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepferd AttcIney for the Urien of Ccncerned Judith H. Johnsrud Scientists DrLwntal Coalition en Nuclear Harren & 'eiss Pcwer 1725 Eye Street, N.W., Suite 506 433 Crlando Avenue Washington, D.C.
20006 State College, Perrsf vania 16801 i
Steven C. Sholly Marvin I. Isds 304 Scurh Market Street 6504 Bradford Terrace Mechanicsburg, Perr.sylvania 17055 Philadelphia, Pennsylvania 19149 Daniel M. Pell, EL W e Marjorie M. Aarredt Anti-Nuclear Grcup Fepreser.1:g Ycrk R. D. 5 32 Scuth Beaver Street Ccatesville, Perraylvaria 19320 Ycrk, Perrsflvarla 17401 Attcrney General of Nea Jersey Gail Bradford Attn: Themu J. Germine, Escuire Anti-Nuclear Grcup Fepreserti g York Deputy Attorney General 245 West Philadelphia Street Divisica of Law - Fcam 316 Ycrk, Pennsylvania 17404 1100 Rayrrnd Eculevard Nesark, Nea Jersey 07102 e
s-w
,