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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] Category:SUBPOENAS
MONTHYEARML20214S0351987-05-29029 May 1987 Subpoena Directing D Feinberg to Appear on 870618 for Deposition Re Allegations.Related Correspondence ML20214S0941987-05-29029 May 1987 Subpoena Duces Tecum Directing Us Dept of Labor to Produce, for Insp & Copying by Gpu,All Documents in Possession, Custody or Control Re Rd Parks by 870609.Related Correspondence ML20213G0571987-05-0808 May 1987 Subpoena.* Subpoena Directing D Feinberg to Appear for Deposition.Certificate of Svc Encl.Related Correspondence ML20213G0521987-05-0808 May 1987 Subpoena.* Subpoena Ordering RA Meeks to Appear for Deposition.Related Correspondence ML20213G0211987-05-0808 May 1987 Subpoena Duces Tecum.* Subpoena for Production of Dept of Labor Documents Re R Parks Complaint.Related Correspondence ML20198S4571986-06-0505 June 1986 Application for Subpoena Directing GL Milhollin to Appear on 860623 in Harrisburg,Pa.Related Correspondence ML20108A9401984-11-13013 November 1984 Application for Issuance of Subpoena Directing Dh Gamble to Appear on 841120 on Behalf of TMI Alert,Inc.Unexecuted Subpoena for Dh Gamble Encl.Related Correspondence ML20108A9711984-11-13013 November 1984 Application for Issuance of Subpoena Directing J Chwastyk to Appear on 841121 on Behalf of TMI Alert,Inc.Unexecuted Subpoena for J Chwastyk Encl.Certificate of Svc Encl.Related Correspondence ML20093H3991984-10-11011 October 1984 Application for Issuance of Subpoena Directing E Zebrowski to Appear for 841113 Deposition in Washington,Dc Re Remanded Issue of Dieckamp Mailgram.Related Correspondence ML20093H4441984-10-11011 October 1984 Application for Issuance of Subpoena & Subpoena Duces Tecum Directing W Lowe to Appear & Produce Documents for 841019 Deposition Re 790329 Pressure Spike.Svc List Encl.Related Correspondence ML20098G4661984-10-0101 October 1984 Application for Issuance of Subpoena Duces Tecum to R Lentz to Appear & Produce Documents for 841010 Deposition Re Dieckamp Mailgram Issue.Related Correspondence ML20098G4711984-10-0101 October 1984 Application for Issuance of Subpoena Duces Tecum to W Creitz to Appear & Produce Documents for 841010 Deposition Re Dieckamp Mailgram Issue & Related Events.Related Correspondence ML20098A1571984-09-19019 September 1984 Application for Issuance of Subpoena Duces Tecum Directing W Yeager to Appear on 841002 in Harrisburg,Pa for Deposition.Related Correspondence ML20097D2641984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to J Chwastyk Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D2151984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to T Illjes Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D2251984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to C Faust Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D2341984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to B Mehler Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D2431984-09-10010 September 1984 Application for Issuance of Subpoena to L Rogers Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D2461984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to L Rogers Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D2501984-09-10010 September 1984 Application for Issuance of Subpoena to J Chwastyk Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D2811984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to H Mcgovern Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D3171984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to M Ross Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D3271984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to G Kunder Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D3471984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to G Miller Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D3531984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to J Herbein Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D3631984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to Rc Arnold Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D3731984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to H Dieckamp Re Dieckamp Mailgram.Proposed Subpoena Encl. Related Correspondence ML20097D3901984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to J Flint Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D4061984-09-10010 September 1984 Application for Issuance of Subpoena to J Flint Re Dieckamp Mailgram.Proposed Subpoena Encl.Related Correspondence ML20097D4211984-09-10010 September 1984 Application for Issuance of Subpoena Duces Tecum to I Porter Re Dieckamp Mailgram.Proposed Subpoena & Certificate of Svc Encl.Related Correspondence ML20071A9891983-02-23023 February 1983 Requests for Subpoenas Directing Cj Heltemes & Fh Rowsome to Testify at 830307 Reopened Hearing.Heltemes & Rowsome Are NRC Staff Members Who Hold Differing Opinions on Feed & Bleed Issue.Certificate of Svc Encl ML19345G5791981-03-18018 March 1981 Request for Subpoena of Agricultural Agents of York & Dauphin Counties J Smith & He Stewart,Since Agents Are Cited in Usda Plan for Nuclear Power Generating Station Incidents. Certificate of Svc Encl ML19344E9921980-09-0303 September 1980 Application for Subpoena Duces Tecum Directed to Rl Curry of York County Emergency Mgt Agency to Give 800917 Deposition & to Bring Log of 800716 Test Exercise.Affidavit & Certificate of Svc Encl.Related Correspondence 1987-05-08
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, UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE ' MATTER OF :
METROPOLITAN-EDISON COMPANY : DOCKET No.' 50-289 (Restart)
(Three-Mile Island Nuclear :
Generating Station, :
Unit-No. 1) :
A.N.G.R.Y. APPLICATION FOR SUBPOENA DUCES TECUM AND NOW, to wit, this day of , 1980, comes ANTI-NUCLEAR GROUP REPRESENTING YORK, by and through its attorney of record, Daniel M. Pell, Esquire in the above matter and moves the Atomic Safety and Licensing Board, by its Chairman, Ivan W. Smith, Esquire and requests the Honorable Board for relief as follows:
1.
On or about August 19, 1980, ANGRY, through its attorney, Daniel M. Pell, Esquire, forwarded a notice of deposition and an accompanying cover letter to Randy L. Curry, Director, York County Emergency Management Agency. A true and accurate copy of.said notice of deposition and letter was duly filed with this Board and made a matter of record. Although by 1
an oversight, a certificate of service was not attached to said )
filings, said documents were served upon the following individuals!
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l?t 60091201 N p
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if iE in
- n Ivan W. Smith, Chairman .. [-
E Dr. Walter H. Jordon, ASLB Member 5 5
E Dr. Linda W. Little, ASLB Member i.
George F. Trowbridge, Esquire I
- I, Docketing and Service Section j, E
U. p. Nuclear Regulatory Commission Executive Legal Director, U. S. Nuclear Regulatory Commission
- 2. ?
on or about August 25, 1980, Randy L. Curry, Director of York County Emergency Management Agency, contacted Daniel M.
Pell, Esquire, through his authorized agent, and informed Daniel M. Pell, Esquire that Randy L. Curry would not be appearing without compulsory process to give his deposition as ,
set forth in the notice of August 19,1980. Certification of this matter is attached hereto, marked Exhibit "A", and is the affidavit of Daniel M. Pell, Esquire to this effect.
Said affidavit is made a part hereof and incorporated herein as though set forth fully herein.
3.
The notifications given in the preceding paragraphs satisfy the requirements of 10 C.F.R. 52.740 (a) which provides:
" (a) Any party desiring.to take the testimony of any party or other person by
- y.
- deposition or oral examination or written '
interrogatori.es shall, without leave of the commission or the presiding officer, give reasonable notice in writing to every other party,to the person to be examined and to the presiding officer of the proposed time and place of taking deposition; the name and address of each person to be examined, if known, or if the name is not known, a general description sufficient to identify him or the class or group which he belongs, the matters upon which each person will be examined and the name or descriptive title and address of the officer before whom the deposition is to be taken."
4.
As set forth in the notice of deposition and the accompanying cover letter which is now a matter of record before this Board, the requested deposition of Randy L. Curry relates to ANGRY's contentions regarding York County's Emergency Plan and its inter-relationship with the plans of the Commonwealth of Pennsylvania, the licensee, and local municipalities. The emergency plan of York County has not yet been finalized, and according to Randy Curry, will be finalized on or after September 1, 1980. This discovery request is therefore based upon new information; and for the further i
reason that the regulatory guidance in this area is continually changing, and this deposition will probably bear upon subsequent guidance issued by the NRC.
7 a
\
.I 5.
The deposition of Randy L. Curry is essential to the preparation of ANGRY's case concerning its cont entions on the York County emergency plan and will also be bas ic to a preservation of emergency planning and preparedness issues or f !
review by this Board. !
6.
10 C.F.R. 52.720 :. .
" Subpoenas", provides authority to this Board for issuing a subpoena duces tecum to Rand y L.
Curry, Director of the York County Emergency Management Agency to appear and give his deposition as to matters contained in
- he notice of deposition, a matter of record before this Board and also to require him to bring with him his log of the emergency exercise conducted by York Count y on July 16, 1980, in conjunction with PEMA and licensee .
Said log has obvious relevancy to these proceedings, since it reflects on the readiness of York County to respond to a nuclear incident occurring at Three-Mile Island.
For all the foregoing reasons, ANGRY requests this Honorable Board through its chairman, to' issue a subpo ena duces
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2 tecum to Randy L. Curry, DirectoJ of the York County Emergency Management Agency, at the York County Court House to appear to give deposition upon oral examination at the I law offices of Daniel M. Pell, Esquire, 32 South Beaver Street, York, Pennsylvania, on the I7 day of $gcmIoM ,
1980, at hiIO o' clock Q .m. and to require him to l
bring with him the log which he kept of the July 16, 1980 test l exercise in which York County coordinated their response with that of PEMA and the licensee.
WHEREFORE, Anti-Nuclear Group Representing York respectfully requests this Board, through its chairman, Ivan W.
Smith, Esquire, to issue a subpoena duces tecum, directed to Randy L. Curry, Director of the York County Emergency Management Agency, at the York County Court House, to appear.to give deposition upon oral examination at the law offices of Daniel M. Pell, Esquire, 32 South Beaver Street, York, Pennsyl-5 piimlau. Y'1g l 7?O, CL .m.
vania, at 9 (30 o' clock on the matter specified in the previous notice of deposition made a part of this proceeding and also to require him to bring with him the log l
which he made of the test exercise dated July 16, 1980, in which York County participated coordinating with the licensee and PEMA.
l Respec submitted, by: [ -~~ Jx --
Daniel M. Pell, Attorney for ANGRY, 32 South Beaver Street, York, PA 17401 (717) 845-6291 x - - _ _ _ - _ _ _ _ - - _
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s COMMONWEALTH OF PENNSYLVANIA )
) ss:
COUNTY OF YORK )
I, Daniel M. Pell, Esquire, having been duly sworn according to law, do depose and state that I am the attorney of record for Anti-Nuclear Group Representing York in the matter of.
Metropolitan bison Company, Three-Mile Island Nt: clear Generating Station, Unit No. 1, Docket No. 50 ,289 (Restart),
and that on or about August 19, 1980, pursuant there,to I sent a notice of deposition along with a cover letter to Randy L.
Curry requiring him to appear in my office to give his deposition upon oral examination.and to bring with him a log of the test exercise in which York County participated in in July, 1980.
I further certify that Randy Curry, through his authorized representative, communicated with my office and indicated that he would not appear nor bring his log without compulsory process. Said cc=munication occurred en or about August 25, 1980, at approximately 10 a.m.
Furth er , the Deponent sayeth not.
/. 2
, . .~-SAj__ a -
D'aniel M. Fell '
Sworn and subscribed to before me this d N [ day of ~ e/}[pjfh*py , 1980.
Kn/EE;:Lv 7. WALT!.t AM g svg %.
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g , wy comm. wen Eores a 3.1981 W _fY f . b hhY-lL -
Norarv PuDi'ic' My Co$:midsion Expires: (SEAL)
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. r CERTIFICATE OF SERVICE I, Daniel M. Pell, Esquire, hereby certify that I ,
I t
served a true and accurate copy of the foregoing ANGRY Appli- :
cation for Subpoena Duces Tecum on the following individuals 7
by placing a copy of same in the U. S. Mails , postage prepaid, !
and addressed as follows on September 8 , 1980.
Executive Legal Director Ivan W. Smith U. S. Nuclear Regulatory Chairman Commission Atomic Safety and Licensing Washington, DC 20555 [
Board Panel j U. S. Nuclear Regulatory Commission Jordan D. Cunningham, Esquire l Washington, DC 20555 Fox, Farr & Cunningham 2320 North Second Street Dr. Walter H. Jordon Harrisburg, PA 17110 881 West Outer Drive ,
Oakridge, TN 37830 Mr. Steven C. Sholly 304 South Market Street Dr. Linda W. Little Mechanicsburg, PA 17055 5000 Hermitage Drive Raleigh, NC 27612 Ellen R. Weiss, Esquire ,
George F. Trowbridge, Esquire Harman and Weiss 1725 I Street, N.W.
Shaw, Pittman, Potts & Trowbridge Suite 506 1800 M Street, N.W. Washington, DC 20006 Washington, DC 20006 Theodore A. Adler, Esquire Docketing and Service Section U. S. Nuclear Regulatory Commissionand Widoff, Reager, Selkowit:
Adler, P.C.
Washington, DC 20555 P. O. Box 1547 Harrisburg, PA 17105 L
b Daniel M.
c.? Man Fell, tsquire c0 m
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Q
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ji BEFORE THE ATOMIC SAFETY AND LICENSING BOA IN THE MATTER OF :
- DOCKET No. 50-289 (Restart) .i METROPOLITAN-EDISON COMPANY : '
(Three-Mile Island Nuclear :
Generating Station, :
Unit No. 1) .
I ANSWERS TO LICENSEE'S INTERROGATORIES l' TO INTERVENOR, ANTI-NUCLEAR GROUP REPRESENTING YORK, ON REVISION TWO OF '
LICENSEE' S EMERGENCY PLAN >
1.
yes Contention 2 (a) is directed to the adequacy of the (a)
(b)
Nuclear Regulatory Commission's which orderOrder doeson restart not dated provide August 9,
~ reasonable 1979 assurance (44 F.R.that47821-25) such resumption can occur without endangering the for the reason that the NRC fails to .
public health and safety, require the development and effectuation of adeq effective radiological emergency response plans.
this contention goes to the fact that the. radiological eme to be brought into compl, lance with applicable standards ofSee Contention II( A) .
adequacy and effectiveness for such plans.
l Consequently, it does not matter whsther Fixedor not the licen Nuclear l
! of Pennsylvania Disaster Operations Plan, Annex E,The contention goes to Facility Incidents.
August 19, 1979 Order itself.
2.
(a) yes (b) The basis of this conclusion that is tois say, identical this with the answer contained in No. 1(b) above; 19, contention attacks the adequacy of the NRC Order dated August 1979, as set forth above to recuire counties to coine into compliance with reasonable DUPLICATE DOCUMENT for county plans as set for Entire document previously ente d into s stem unde :
ANO _
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i 4L No. of pages:
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