ML20126C808
| ML20126C808 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/16/1980 |
| From: | Aamodt M AFFILIATION NOT ASSIGNED |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML20126C812 | List: |
| References | |
| NUDOCS 8004100136 | |
| Download: ML20126C808 (5) | |
Text
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February 16, 196 e l
OGQ s
United States of America 5
E D Nuclear Regulatory Commission e@g Eefore the Atomic Eafety and Licensing Board C-In, the Matter of Metropolitan Edison Company, Three Mile Island en
Nuclear Generating Station, Unit No. 1, Docket 5C-289 Restart
.4:.:..v.
- Aamodt First ' Set). of Inteirogatoriest.toeLicensee c
Metrocolitan Edison Comtany 1.
In Metropolitan Edisen Recommended Reovirements for Restart of_.
Three Mile Is1hri Nuclear Station Unit l Emergency Plan, Section 4, Annex E, Commonwealth of Pennsv1vania Dtaster Oreration Flan, Appendix D '
there is a pege entitled Derartment of Agriculture Flan Fixed Nuclear Incility *rry
.t Plan (limited Distribution under Separate Cover).
The
,gatories concerning that plan are filed pursuant to 10 CFR 2, ch requires that the interrogatories be anssered separate 1) ly in writing and under oath or affirmation.
The plan has.e.tationship to Aamodt Contentions 4 and 5. The Board's office informed me February 15,19Eo that your offices are to assist me in obtaining the plan.
I made an initial request on January 31 as stated p. 7 Intervenor' Aamodt's Respense to licensee's Objections
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to Emergenc'y Planning Contentions.
Robert Cahler called on February 1, 1980 as reported en p. 7 3.r.
Zahler, attorney for I.et Ed, asked me not to centact anyone else at ket Ed in obtaining this plan.
He said I should not talk with anyone at Gilbert Associates or anyone but ccunsel at met Ed.
I again spoke with dr. Zahler on h ednesday, February 13,198C in harristurg at the Lecond Fre-hearing Conference and requested a copy of this plan.. Met Fd or their counsel have not centacted me to date regarding the accessibility of this plan.
The ccarlete lack of concern: Met Ed has disp]$yeU in the interests of.
the farming community has intensified my eYf6rfs.-, Thibkin.my opinien, substantive 1: roof that Met Ed is only intertrsted Th~th'eir econom.ic
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800R0Qs3 13 C.
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2 viability and has no concern for health, safety and welfare of the people who live in the area s'urrounding TMI.
Mr. Trowbridge entered the financial concerns of Met Ed into hearing, even mentioning the cost of the plant.
He referred to the hehhing as an ' Alice in
%onderland" affair hich I interpreted as an attempt to disparage the several and diverse efforts of intervenors to protect their i
health and safety.
Since I hhie not received sn agricultural emergency. plan, request ~has been made directly to the Commonwealth of Pennsylvania in a set of interrogatories.
The following questions are directed to licensee 1.
Is there an agricultural plan referred to in Section 4, Annex E Emergency Planning, Resocnse to Restart as Derartment of Agriculture l
Ilan Fixed Ndelear Facility Incident Flan?
If so, provide.
2.
ihis agricultural plan is noted as" Limited Distribution under teparate Cover".
a.
Why is distribution limited?
Unhol b.
On what basis wasgdistributien decided?
c.
After.my reqbest on January 31, 1980 to'obtain a copy of this plan, what efforts did you cake to fulfill this request?
3.
Frovide names and credentials of those members of Ket Ed who are working with the Department of Agriculture on this plan.
4'.
Do you have any figures on the value of the livestock, farmland and agricultural products included in the ten mile and fifty mile EF7s of C41?
then were these figures obtained by you?
a.
b.
Frem whom did you obtain them?
Respectfully submitted, 4
7
.-m.
f
- li,rAl
$1, {O4mh
- Marforie M. Aamodt February 18, 1980
~.
February 20, 1980 UNITET< STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, Three Mile. Island Nuclear Statio Unit No.
1, Docket No. 50-289 CERTIFICATE OF SERVICE Ihereby certify that copies of "Aamodt First Set of Interrogatori'es to Licensee Metropolitan Edison Company" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 20th day of February, 1980.
AAW m
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February 20, 1980
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ConR spo f ~-.
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R DOCGTED USNRC
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a-q UNITED STATES OF AMERICA 2
N> Y4 NUCLEAR PEGULATORY COMMISSION Ma of b Secretary E
m*% a s a Bm(h 6
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD "
,o y
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
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(Res tart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Ivan W. Smith, Escuire Chan John A. I.evin, Esquire Atomic Safety and Licensing Assistant Counsel Board Panel Pennsylvania Pcblic Utility Ccrm'n U.S. Nuclear Regulatory Cc:Imission Post Office Ecx 3265 Washington, D.C.
20555 Harrisburg, Pennsylvania 17120 Dr. Walter H. Jordan b*
Atcmic Safety and Licensing Assistant Attorney C+.neral Board Panel -
Post Office Sex 2357 e
37830.
E sW, Pesyle 17120.
Dr. Linda W. Little John E. Minnich GM M
Co q Bo d atomic Safety and Licensing of Ccr:missicners 50 Drive N
Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 Jartes R. Tourtellotte, Esquire office of the Executive Legal Director Walter W. Cohen, Esquire U. S. Nuclear Regulatory Ccnmission Consumer Advocate Washington, D.C.
20555 Office of Consu:Ter Advocate 14th Floor, Strr/cerry Square Docketing and Service Section Harrisburg, Pennsylvania 17127 Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C.
20555 l
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9
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Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry 'Itranship Attorney for People Against Nuclear T.M.I. Steering Ccanittee Energy 2320 North Second Street Sheldon, Harnen & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006 Theodore A. Adler, Esquire Widoff Paager SelkcWitz & Adler Robert Q. Pollard Post Office Box 1547 Chesapeake Energy Alliance Harrisburg, Pennsylvania 17105 609 Montpelier Street Baltimore, Maryland 21218 Ellyn R. Vbiss, Esquire Attorney for the Union of Conca. red Chauncey Kepford Scientists Jtrlith H. Johnsrud Sheldon, Harron & Weiss Envircrrnental Coalition on Nuclear 1725 Eye Street, N.W., Suite 506 Pcwar Washington, D.C.
20006 433 Orlando Avenue State College, Pennsylvania 16801 Steven C. Sholly 304 South Market Street Marvin I. Icais 1bchanicsburg, Pennsylvania 17055 6504 3radford W rrace Philidelphia, Pennsylvania 19149 Gail Bradford
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Holly S. Keck
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legislation Chairn'an George F.
Trowbridge'
' Anti-Nuclear Group Fapresenting York Shaw, Pittman, Potts & Troubridg 245 West Philadelphia Street 1800 M Street, N.
W.
York, 7ennsylvania 17404 Washington, D. C.- 2 0 0 3 6.. -
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