ML19344D595
| ML19344D595 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/20/1980 |
| From: | Aamodt N AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19344D583 | List: |
| References | |
| NUDOCS 8004250081 | |
| Download: ML19344D595 (1) | |
Text
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March 20,1980 Unitcd States of Amei-ica Nuclear Regulatory Commission Before the Atomic Safety and Licensing Board In the Matter of Metropc litan Edison Company, Three Mile Island Nuclear Ststiom Unit 1, Docket 50-289 AAMODT RESPONSE TO MCENSEE'5 OBJECTIONS TO THE SECOND LET OF INTERROGATORIl
- Contrary to Licensee's objections, the subject interrogatories do relate to Aamodt Con"tention 6.
As Licensee correctly notes, Contention 8 is limited to short tem Recommendat' ion 5 which states, "the Licensee shall demonstrate that the waste management capability including
- storage and processing for solid, liquid and gaseous wastes is adequate to assure safe operation..."
Before there can be assurance that capability is adequate, quantities to be handled must be reliably defined.
Intervenor challenges Licensee's assessment of quantities of radioactive materials, released both routinely and eer:identally under "nomal" operating condi-tions and, therefore, challenges ca.pability under projected waste manage-ment mechanisms.
Regarding Licensee's interrogatories 8-3 and 8 4 as discussed in subject objections, Intervenor holds as above that one must know how much is required to be stored and/or processed before one can be assured that the capability exists to assure safe operati'on.
Simply stated, one j
must know how much garbage will be g'enerated before one buys garbage cans.
For the above reasons Intervenor holds that
(
1.
Licensee should respond to subject interrogatories, 2.
Intervenor cannot respond to Licensee interrogatories 8-3 and 8-4 lacking requested information.
oclea inferring "not limited to" U
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Respectfully submitted, f
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