ML19296D060

First Set of Interrogatories Directed to Met Ed.Requests Info Re Individuals to Be Called as Witnesses & Individuals Who Drafted Emergency Plan.Includes Inquiry Re Role of County Civil Defense in Plan Review.Certificate of Svc Encl

ML19296D060
Person / Time
Site:	Three Mile Island
Issue date:	02/15/1980
From:	Cunningham J FOX, FARR & CUNNINGHAM
To:	METROPOLITAN EDISON CO.
Shared Package
ML19296D052	List: ML19296D049 ML19296D060
References
NUDOCS 8002290295
Download: ML19296D060 (9)

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, UNITED STATES OF AMERICA

, NUCLEAR REGULATORY CCM'tISSION I H BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD l

'l IN THE MATTER OF: .

METROPOLITAN EDISON C05tPANY  : Docket No.30-289 (Three Mile Island Nuclear  : (Restart) lPowerStation, Unit No. 1)  :

I NEWBERRY TOWNSHIP DtI STEERING COMMITTEE'S FIRST SET OF INTERROGATORIES TO LICENSEE METROPOLITAN EDISON l

j These Interrogatories are filed by the Newberry Township TMI 1

Steering Committee.

1. State the name, address, position and occupation, place of employment and subject matter of testimony of all witnesses who will be called by Met Ed in this proceeding to testify on any aspect of Met Ed's I

I Emergency Plan for the Three Mile Island Nuclear Station.

ANSWER:

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h f 2. For each person named in response to Interrogat.ry No. 1 above who will testify to matters of opinion based upon ascerted expertise and so=e recognized discipline, profession or occupation, state all I educational institutions attended af ter secondary school, all undergraduate i

h and graduate degrees granted, areas of concentration, titles of thesis,

professional articles and books authored or co-authored; caption, docket l

number, date, place and subject matter summary of any prior testimony in i

i any state or federal judicial or administrative proceeding, s well as the i name of the party for whom appearing. Moreover, state the subject matter P

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on which the witness is expected to testify; and state the substance of J

] the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion.

l ANSWER:

3. State the name, address, position and occupation, place of employment of each individual who participated in the drafting of the Emergency Plan for the Three Mile Island Nuclear Station.

ANSWER:

i 4. Did any of the individuals who participated in the drafting I

of the Emergency Plan meet with any County of ficials to elicit opinions from

! them with regard to the Emergency Plan?

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ANSWER:

5. If so, state:

(a) the names of the individuals who met w".th the County i officials;

(b) the names of the County officials who were contacted by ,

I I i 6 the individuals referred to in sub-paragraph (a) above; 6

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l (c) the dates on which these meetings took place;  !

!l (d) the reason for the meetings with the County officials.

ANSWER: l

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l, 6. Did any of the individuals involved in the drafting of the Emergency Plan meet with any State or Federal officials?

l ANSWER:

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7. If so, state:

(a) the individual who met with the Federal or State agencies; i

! (b) the date on which the Federal or State agencies were l

l contacted; I!

ll (c) the substance of the discussions that took place I

! cetween the individual and the State or Federal i

l agency; (d) the reason why the Federal or State agency was contacted; (e) the name of the person who was contacted at the

l n Federal or State agency.

ANSWER:

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O S. State whether you have ever conducted any studies with regard

, to the Emergency Plan concerning traffic flow in the event an evacuation l was ordered in the event of an emergency.

ANSWER:

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l l 9. If so, state:

(a) the date on which the study was conducted:

(b) the person who conducted the study; l

(c) the findings of the study; (d) whether the study was reduced to writing. If so, attached a copy of this report to your answers to these interrogatories.

ANSWER:

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10. Are you making any adjustments to the Emergency Plan in i

I light of the recent Rogovin Report to the Nuclear Regulatory Commission, which recommended at ten-mile radius for evacuation of citizenry in the l

l event or an emergency condition existing?

I ANSWER:

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11. If so, please state the amendments or adj ustments made to l!

[ the Emergency Plan.

ANSWER:

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• l ll h 12. As regards volunteer firemen and policemen, and local police a i y departments, besides the letters of agreement attached to the Emergency Plan, i

I what guarantees do you have that such personnel will submit themselves to l l

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your service in the event of an emergency?

i ANSWER:

13. In the event that voluntary personnel did not respond to your requests for aid in times of an energency, please state how you would respond to the situation.

ANSWER:

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14. Specifically state the premise.s and grounds on which you answer the preceeding interrogatory. If there are studies available, please indicate the er.istence of those studies and attach a copy of the studies that you have in your possession to your answers to these interrogatories.

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15. What provisions have been made for the training of National l Guard personnel that you rely upon being in place in the event of an

!! emergency condition?

ANSWER:

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i 16. State whether, with regard to the National Guard personnel, li any protective gear has been purchased to protect National Guardsman it.  !

i the event of an emergency.

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17. Did you forward to County Civil Defense offices that surround j the Three M'le Island Nuclear Station copies of the revised Emergency Plan?

N4SWER:

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! 18. If so, state:

(a) the dates on which you forwarded the revised Emergency Plan to the County Civil Defense offices; (b) state the offices which you forwarded a copy of the Emergency Plan to; l

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! (c) state whether any local Civil Defense office has offered comments, either oral or written, to .ne l Emergency Plan; (d) state whether these comments were ever reduced to I i writing, and if so, attach a copy of all such writings i l

j that you have in your possession to your answers to i.

p these interrogatories.

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ASSWER:

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!l h 19. What provisions have you made for in the Emergency Plan for l; I the evacuation of farm animals?

! ANSWER:

l I j 20. Did you ever have any studies undertaken to determine the I

exact number of hours it would take to evacuate all of the citizenry from l a ten-mile radius from the Three Mile Island Nuclear Station in the even i

I i of an emergency condition?

ANSWER:

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21. If so, please attach a copy of all reports relating to this '

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[ matter that you have in your possession to your answers to these interroga-I tories.

22. Did you ever attempt to verify facts or assumptions made in the County plans which were attached and made part of your Emergency Plan?

ANSWER:

q 23. If so, please state:

(a) the names of the individuals who made the verifications; ll I

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(b) whether any of the facts or assumptions made in the d

l County plans were found to be erroneous; i l

'h (c) set forth those facts and assumptions found to be 1 i erroneous in the County plan in specific detail. l l ANSWER:

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24. Did you ever attempt to coordinate the five county plans ,

which are incorporated by reference to the Emergency Plan? If so, please state what attempts were made to coordinate the various plans.

ANSWER:

, 25. Did you ever attempt to coordinate the orc;ite emergency plan with those of the five surrounding counties which are incorporated by reference into the Emergency Plan?

i i ANSWER:

26. If so, state what attempts were made to coordinate onsite emergency plan with those of the five counties.

ANSWER:

t FOX,..FARR 5.CUNMINGHAM ,-'

BY: . -

c J'rdan D. Cunningham, Esq.

Attorney for Intervenor 2320 North Second Street DATED: February 13, 1980 Harrisburg, PA 17110 l

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UNITED STATES OF AMERICA E,7p p p NUCLEAR REGULATORY CCMMISSION y 9

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BEFORE THE ATOMIC SAFETY AND LICE'4 SING BOARD 's-(. ,

ijf In the Matter of:  :

METROPOLITA'i EDISON COMPANY,  : Docket No. 50-289 et al.  :

(Three Mile Island Nuclear  : Restart Station, Unit No. 1)  :

CERTIFICATE OF SERVICE I hereby certify that a copy of Interrogatories to Licensee was mailed First Class, postage prepaid, this 15th day of February , 1980, to the following:

Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Chief, Docketing Service Section Ivan W. Smith , Chair:.an Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commissicn Washington, D.C. 20555 Doctor Walter H. Jordan 881 West Outer Drive Oakridge, Tenn 37830 Doctor Linda W. Little 5000 Hermitage Drive Raleigh, NC 27612 George F. Trowbridge, Esq.

SHAW, PITTMA'i, POTTS & TROWBRIDGE 1800 M. Street, N.W.

Washington, D.C. 20036 Ja es A. Tourtellotte Office of Executive Legal Director U. S. Nuclear Regulatory Co= mission Washington, D.C. 20555 ,

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/;- Jordan D. Cunningham, Esq.

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