ML19309A703

First of Set of Interrogatories.Interrogatories Limited to Contention 8 Re Emergency Planning & Preparedness. Certificate of Svc Encl

ML19309A703
Person / Time
Site:	Three Mile Island
Issue date:	02/25/1980
From:	Sholly S AFFILIATION NOT ASSIGNED
To:	DAUPHIN COUNTY, PA
Shared Package
ML19309A704	List: ML19309A703 ML19309A706 ML19309A708 ML19309A709
References
NUDOCS 8004010036
Download: ML19309A703 (6)

Text

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UN1IED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e e In the Matter of )

). ( .g' MEIROPOLITAN EDISON COMPANY Dock No 50-289 ooc (o

(Three Mlle Island, Unit 1)

__. FEB 2 71980 >

Office of the Secretary 7-l INIERVENOR STEVEN C. SHOLLY FIRST Docketing & Senice SEI 0F INTERROGATORIES TO DAUPHIN COUNTY y

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4 to Pursuant to 10 CFR 2.740, Intervenor Steven C. Sholly hereby files the following interrogatories with Dauphin County, a participant in this proceeding under 10 CFR 2.715.

Interrogatories are limited to Sholly Contention #8, relating .

l to Emergency Planning and Preparedness.

Interrogatories are to be answered fully, in writing, and under oath by any officers of the County who have direct personal knowledge of the facts sought by these interrogatories. The answer to each interrogatory is to contain the names and identifications of the persons supplying the answers. All documents relied upon in providing an l answer to an interrogatory are to be referenced according to title, authors, source of the documents, and page numbers l uttilzed in supplying the answer. These interrogatories are to be supplemented as required by NRC regulations.

8004010036!

08-001--The Dauphin County Office of Emergency Preparedness

" Action And Response Plan For Emergency Personnel And Citizens , April 1976," (hereafter referred to as the Dauphin County Plan) is appended to the Licensee's Emergency Plan. As such, Licensee is functionally dependent upon Dauphin County to ensure that the pubile health and safety is adequately protected in the event of an emergency at TMI. Discuss the extent to which officials from the Licensee have participated in the preparation of the Dauphin County Plan. Be as specific as possible regarding when such assistance occurred and the form which the assistance took.

08-002--Discuss the extent to which the Dauphin County Plan )

has been coordlated with other county plans and the Commonwealth of Pennsylvania Disaster Plan, Annex E, to ensure that evacuation routes are not planned to be utilized by more than one county, and that there is not dupilcation in the planned use of host reception areas.

08-003--Identify the assumptions upon which the Dauphin l County Plan is based, specifically those assumptions l relating to the time available in the event of an

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emergency at TMI to implement the Dauphin County Plan.

Where Licensee has provided specific time estimates for lead times to implement the Plan, provide these time estimates and specify the persons supplying the estimates and when they were supplied to the County.

08-004--The Dauphin County Plan estimates the number of persons in Dauphin County within 10 miles of the TMI site as 127,000. NRC documents (specifically, "Beyond Defense In Depth") cite the total population within 10 miles of TMI as being less than 120,000 (Beyond Defense In Depth is NUREG 0553) . What is the source of the 127,000 figure presented in the Dauphin County Plan?

08-005--The Dauphin County Plan contains numerous emergency plans for indtvidual political subdivisions (i.e.,

the Conewago Township Emergency Plan, the Derry Township Evacuation Plan, etc.) . To what extent has Dauphin County investigated to see whether these individual municipality emergency plans conflict with i

l one another? If any such conflicts have been identified, describe each such conflict.

08-006--According to newpaper accounts, a full-time staff person from PEMA has been assigned to Dauphin County to work on

i a revision to the Dauphin County Plan. Identify the PEMA staff person assigned to Dauphin County. Was this assignment requested by Dauphin County 7 If so, when was the request made?  !

08-007--Has the Licensee ever requested Dauphin County to prepare an emergency plan covering possible events at IMIT If so, state when such a request was made and by whom.

08-008--The Dauphin County Plan appears to address only evacuation as a means of protecting the public health and safety in the event of an accident at IMI. To what extent will the revised Dauphin County Plan address other potential protective actions which may be necessary?

Respectfully submitted,

< h)r:,e l$ k'  ;-

Steven C. Sholly 304 South Market Street Mechanics burg , PA 17055 h--717-766-1857 w--717-566-3237 DATED: 25 February 1980

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UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION 9 0 te

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g In the Matter of Dock No. 50-289 MEIROPOLITAN EDISON COMPANY (Three Mile Island, Unit 1)

CERTIFICATE OF SERVICE I hereby certify that single copies of INIERVENOR STEVEN C.

SHOLLY FIRST SEI 0F INIERROGATORIES TO DAUPHIN COUNIY were served upon the persons on this service 1Lst by deposit in the United States Mall, postage prepaid, on this 25th of February 1980.

. , ._ [, /4 13 Steven C. Sholly /

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r Ivan W. Smith, Esq. Docketing and Service Section Chairman, Atomic Safety and Office of the Secretary Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 John A. Levin, Esq.

Dr. Walter H. Jordan Assistant Counsel Atomic Se.fety and Licensing Pennsylvania Public Board Panel Utility Commission 881 West Outer Drive P.O. Box 3265 Oak Ridge, TN 37830 Harrisburg, PA 17120 Dr. Linda W. Little Karin W. Carter, Esq.

Atomic Safety and Licensing Assistant Attorney General

Board Panel Commonwealth of Pennsylvania 5000 Hermitage Drive 505 Executive House Raleigh, NC 27612 P.O. Box 2357 Harrisburg, PA 17120 James A. Tourte11otte, Esq.

Office of the Executive Legal Director (OELD)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Wg

l John E. Minnich Holly S. Keck Chairman Legislation Chairman Dauphin County Board of ANGRY Commissioners 245 West Philadelphia Street Dauphin County Courthouse York, PA 17404 Front and Market Streets Harrisburg, PA 17101 Robert Q. Pollard Chesapeake Energy Alliance Walter W. Cohen, Esq. 609 Montpelier Street Consumer Advocate Baltimore, MD 21218 Department of Justice 14th Floor, Strawberry Square Chauncey Kepford Harrisburg, PA 17110 Erxironmental Coalltton on Nuclear Power Jordan D. Cunningham, Esq. 433 Orlando Avenue Attorney for Newberry State College, PA 16801 Township TMI Steering Committee Marvin I. Lewis 2320 North Second Street 6504 Bradford Terrace Harrisburg, PA 17110 Philadelphia, PA 19149 Theodore A. Adler, Esq. Marjorie M. Aamodt Attorney for TMIA R.D. # 5 Widoff, Reager, Selkowitz, Coatesville, PA 19320 and Adler P.O. Box 1547 George F. Trowbridge, Esq.

Harrisburg, PA 17105 Attorney for Licensee Shaw, Pittman, Potts, &

Ellyn Weiss, Esq. Trowbridge Sheldon Harmon, & Weiss 1800 M Street, NW l Attorney for UCS Washington, D.C. 20036

Suite 506 1725 I Street, NW Washington, D.C. 20006 Karen Sheldon, Esq.

Sheldon, Harmon & Weiss Attorney for PANE Suite 506 1725 I Street, NW Washington, D.C.

20006 1

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