ML19344D582

Response in Opposition to Licensee Objections to Aamodt 800225 Third Set of Interrogatories.Asserts That Appropriate Relationship Exists Between Interrogatories & Contention 4 Re Restart Proceeding

ML19344D582
Person / Time
Site:	Three Mile Island
Issue date:	03/20/1980
From:	Aamodt N AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19344D583	List: ML19344D582 ML19344D591 ML19344D595
References
NUDOCS 8004250063
Download: ML19344D582 (2)

Text

Karch 2C, 1980

/g[

2 ""6 APR imp.o298Gr@'-

Unitcd States of A:horica b'- edth Nuclear Regulatory Commicsion ctuc%(g;[$/

0: s e / Before the Atomic Safety and Iicensing Board

.9 In .er of Metropolitan Edison Company. Three Mile Island Unit 1 Docket 50-289 (Restart)

AAMODT RESFONSE TO LICENSEE'S OBJECTIONS TO THE THIRD (SIC: SIXTH) SET OF INTERROGATORIES DATED February 25,198r Intervenor is at a total loss to comprehend any logic which could heve been operative in Licensee's decision to present the subject ob- ,

jections. We assert that each interrogatory bears an appropriate relation- ;

ship to Contention 4 and is within the scope of the hearing for the follow-ing reasons:

a. Interrogatory 4 - NUREG 0396 provides the basis for requiring

" sheltering" of population (as opposed to evacuation) and protection of l foodstuffs beyond the 10 mile EFZ to a 5c mile perimeter. Timely disse =-  :

ination of appropriate information is needed for both of these actions.

In simple tems, one must know where potential contaminants are expected.

to be found before one can take protective action.

b. Interrogatory 5 - same as (a).  :

c. Interrogatory 6 - Same as (a), adding the consideration that l i'

ovacuation of the 1C mile EPZ complicates response and, therefore, must l

ba considered. ,

d. Interrogatory 7 - The August 9 Notice and Order of Hearing, page 6 section 3/d, requires adequate "f.i t" of several emergency plans "so as

-l to assure the capability to take energency action." The time needed to j take appropriate action (within or without the 1C mile EFZ) is a function -

of Licensee's responses to Interrogatories 7 and 8. Further, subject matter raised in Interrogatories 7 and 8 relates to potential aberrations in evacuation procedures which could cause a total lack of assurance that cmergency action could be effectively carried out.

i 8 0042 50 Olo)

. 2

e. Interrogatory 9 - Preliminarily, the argument for (d) apply.

Fur ther, it must be evident to Licensee, since Licensee has ' spent heavily in public relations, that the public will respond to a given situation in accordance with its learned perceptions. This interrogatory deals with the end result of information flow, (Will it be acted on?) a key clement in providing assurance of the capability to take emergency action.

f. Interrogatory 10 - licensee's objection is frivolous. Clearly i

this does not relate to additional manp war resources. Rather, the board ;

allowed the revision to Contention 4 which dealt with data transmission from " plant operating personnel'. .immediately. . . to the NRC . . ." Simply  ;

~

stated, this interrogatory deals with the question, "Who will be avail-oble to do what?", with this added burden placed on Licensee'.

Respectfully submitted,

l. ./

/ / Y k k&t h hMA Y Norman O. Aamodt l

l 1

.