ML19323A610

Responses to Aamodt First Set of Interrogatories.Includes Info Re Agricultural Emergency Plans.Affidavits & Certificate of Svc Encl

ML19323A610
Person / Time
Site:	Three Mile Island
Issue date:	03/19/1980
From:	Carter K PENNSYLVANIA, COMMONWEALTH OF
To:	Aamodt AFFILIATION NOT ASSIGNED
References
NUDOCS 8004210453
Download: ML19323A610 (25)

Text

.

u ~ scwe mewm ._

I C /<

UNITED STATES OF AMERICA Of C 20% \

WCIEAR REGULAIORY CaHISSIm R!a ,i BEFORE THE ATQHC SAFEIY AND LICENSING BOARD 6 'fAR 2'7 Eb p4jS?w  ;

In the Matter of )

% +>g -

NEITAN EDISW CWPANY, Docket No. 50-289 b

• "' }

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

Cat 0NWEAL'IH'S RESFWSE TO AAFDDI INIERROGATOFlES (FIRST SEI)

Answers of David S. Ingraham, V.M.D.

2. Are there any other agriculture emergency plans pertinent to the scope of this contention?

RESPONSE

No.

6

11. Is any revision being made for potassian iodide for cows and other livestock for thyroid protection?

j EESPONSE No.

12. Are there criteria for deciding for or against t evacuation of livestock?

RESPONSE

We are not making plans to evacuate livestock.

17. Is there any provision presently available or planned for cmpensation for loss of livestock?

RESPONSE, To my knowledge, there is no state indemnity progran for losses incurred by radiation.

8004210Y63 .

19. Did you consider on March 28, 1979 or anytime thereafter to evacuate livestock in the 'IMI area?

RESPONSE

No. '1he possible need for evacuation was discussed in preliminary

~

discussions; however, there were no plans made to evacuate livestock.

Respectfully submitted, t

.l  ;

'. Ib N/ O-] 0L >

KARIN W. CARIER Assistant Attorney General Dated: March 19, 1980

~

0 4

'. asygI;gn cogBE,SP.ONDENCS UNITED STATES OF AMERICA NUCLEAR REGlH.ATORY 00bHISSION BEEDRE THE AINIC SAFE 1Y AND LICENSING BOARD In the Matter of' )

)

MEIROPOLITAN EDISON 034PANY, ) Docket No. 50-289 ~~

~

N

) (Restart) f, (Three Mile Island Nuclear ,)

Station, Unit No. 1) ) De c:; m a S u:::.=:c

-h AFFIDAVIT OF DAVID S. INGRAHAM, V.M.D. [."' f,Vo

• "io n IO3'J) ~.l 02:cf23s[h,7 E'@c& ' 1 r comonwealth of Pennsylvania )  % 2'ICII

) 6 N oY County of Dauphin )-

DAVID S. INGRAHAM, V.M.D., being duly sworn according to law, deposes and says that he is Director of the Bureau of Animal Industry, Pennsylvania Department of Agriculture; and that the information contained -

in.the Coninonwealth's Response to Aamodt Interrogatories (First Set) nunbered 2,11,12,17, and 19 (for contention 5) is true and correct to the best of his knowledge, information and belief. -

/ , // Y

^

05 C' ' Qh ..

DAVID S. INGRAHAM, V. .D.

Director /

Bureau of Animal In try PA Department of Agriculture Sworn to and subscribed before me this /fqby of March, 1980.

.- /Yf/.A un g&

y >pp X

~

.'No,tary Public (_ r g .,r,,;;.. ,: -;SW

7. ,

(,, . c::3 r :, u !.h .' 17. 1732 pg.cw, PA Dr.-/i Cca*!? l r

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) +

)

, METROPOLITAN EDISCN COiPANY, ) Docket No. 50-289

.) (Restart)

(Three Mile Island Nuclear )

Station, thit No.1) )

Cat 0NWEALTH'S RESPONSE TO 1 AAbODI INIERROGATORIES (FIRST SET)

Answers of Wallace C. Evans  !

6. How many farms are located in the ten mile radius around IMI?  ;

i

a. How many acres does this comprise?  !

b. he is the estimate of the total value of the land? ,

c. h t is the estimate of the value of farm products? ,

d. ht is' the estimate of the value of milk produced?

RESPONSE '

Agricultural statistics are not cmpiled in radial units. The smallest level of statistical data available to the Agricultural Department are county statistics for major cmmodities. Subcounty statistics may be -

available from township tax records; however, township boundaries do not l

, coincide with radial distance boundaries. '

f

7. How many farms are located outside of the ten mile radius and within the fifty mile radius of IMI?

a. How many acres does this emprise?

b. ,

h t is the estimate of the total value of this land?

c. h t is the estimate of the value of farm products?

d. h t is the estimate of the value of milk produced?

I .-

. 1

RESPONSE

The Agriculture Department has no data and is unawara of other data, sources to respond to this question.

l i

8. What is the total indebtedness of the fam canunity in the ten and l fifty ud.le radii of M? '

i

RESPONSE

The Agriculture Department has no data and is unaware of other data

~

sources to respond to this question. -

i

9. How many of each kind of livestock are estimated to be on these farms,  ;

including dairy cows, other cattle, horses, sheep, pigs, goats, chickens and other poultrf? Give for the ten mile radius and fifty  ;

mile radius of M .

sRESPONSE i The Agriculture Department has no data and is unaware of other data sources to respond to this question.

10. How many cattle trucks are available in the ten mile radius of M ?

In the fifty mile radius? , i RESPGEE i The Agriculture Department has no data and is unaware of other data sources to respond to this question.

18. How would evacuation of livestock impact on the agricultural emnunity in the M area? ,

a. How would consuner concern affect that impact?

b.

~

How would radiation contamination affect that impact?

RESPONSE, ,

The Agriculture Department has no data and is unaware of other data sources to respond to this question.  !

16C. Has the M -2 accident effected the flow of credit to farmers?

a. Has there been any caution denenstrated or expressed by private or federal banks? .

b. Would you expect some erosion of credit if there were a ntmber i of reportable accidents of less than Class 9 category at M 7  !

c. Would you expect erosion of credit if there was another Class 9 accident at M 7  :

l

RESPONSE

The Agricultiure Department has no data to respond to this quer , ion.

Perhaps the Farmers Hme Administration of the thited States Department of Agriculture has some basis for responding to this question.

i 16D. How dependent on credit for production costs (including machinery) i are farmers in the M area? i

a. Express in dollars borrowed annually.

t

b. Express in nunber of farms that be removed frcxn production.

c. What is the average and median debt of farmers in the ten mile radius of M ?  :

t RESPCtGE The Agriculture Department has no data to respond to this question. [

Perhaps the Farmers Home Adninistration of the thited States Department of Agriculture has see basis for responding to this question.

Respectfully submitted,

(% 'd / ( ). b45.b-i YWEN W. CARTER Assistant Attorney General Dated: 8 arch 19, 1980 LNITED STATES OF AMERICA MJCLEAR REGULATORY 02filSSION BEFORE THE AICNIC SAFE 1Y AND LICENSING BOARD In the Matter of ) y

)

MEIROPOLITAN EDISON ONPANY, ) Docket No. 50-289

) (Restart) -

(Three Mile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF WALIACE C. EVANS O-mwealth of Pennsylvania )

)

County of Dauphin )

WALIACE C. EVANS, being duly sworn according to law, deposes and says that he is Statistician-In-Charge, Crop Reporting Service, Pennsylvania Department of Agriculture; and that the information contained in the Comonwealth's Respoase to Aamodt Interrogatories (First Set) n mbered 6, 7, 8, 9,10,18,16C, and 16D (for contention 5) is true and .

correct to the best of his knowledge, information and belief.

Yk i a}_('a a -

'75 w WA:1. ACE C. EVANS Statistician-In-Charge '

Crop Reporting Service  :

PA Department of Agriculture Smrn to and subscribed before rm this /f'fday of March,1980. ,

mcrxih)$xcirue Notary Public (

L

^

se,,-- c. ! ce . !* - ; Mk o.vg c.ca.w. u:,c ..*.: a n. m1 1:aa:'.,u;. P.*. Da$in Cozy

' - - - - ~ ~ _ _ _

l 8EIAmu QDRBESPOND UNITED STATES OF AMERICA NUCLEAR REGUIATORY 00bHISSION BEEURE THE ATIMIC SAFELY AND LICENSING BOARD In the Matter of )

) s

~~

MEIBOPOLITAN EDISON COMPANY, ) Docket No. 50-289f ,

) (Restart) -

(Three Mile Island Nuclear ) -

Station, Unit No. 1) ) $ t , -

y I."AR 2 7 eg: > c.)

00btDNWEAIMI'S RESPONSE TO O!3:3 cf t.ta S:::t q "l AAbOI7f INIERROGATORIES (FIRST SEI) NOU! 10 S ."d:a O~

e w, Answers of Imroy C. Corbin, Jr.

• i 2a. How are vegetables and fruit selected for sanpling in terms of distance and direction from TMI?

RESPONSE

Sanpling was based on availability within a 7-mile radius of 1MI.

Sanpling locations were Northwest, Northeast, East and Southeast.

2b. At what locations are these measurements made?-

RESPONSE

Middletown, Bainbridge, Etters, Harrisburg.

Respectfully submitted,

. <t M . . Il ' 0KLY L*

KARIN W. CAtut.K Assistant Attorney General Dated: March 19, 1980 E

m3

UNI'1ED STATES OF AMITTCA NUCLEAR REGUIAIDRY 00tH1SSION . bed 2ERE9 " N M BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

. MCrROPOLITAN EDISON C0t!PANY, ) Docket No. 50-289 .

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) ), ,

AFFIDAVIT OF LEROY C. CORBIN, JR.

Conmxwealth of Pennsylvania )

)

County of Dauphin )

LEROY C., CORBIN, JR., being duly sworn according to law, deposes and says that he is Chief of. the Division of Food Control, Pennsylvania Department of Agriculture; and that the information contained in the Countxwealth's Response to Aamodt Interrogatories (First Set) nunbered 2a and 2b (for contention 4) is true and correct to the best of his knowledge, information and belief.

LEROY C. CORBIN, JR.

Chief, Division of Food Control PA Department of Agriculture Sworn to and subscribed before ne this day Ed D.

of March,1980. //

h'es*

coc: , - .-

01

w. .. ;a Y.C,. ,.

Notary Public 2 ISAR E 7 C _^2 y

~

'6- cir:g c3 g. ,.c, , 7 Dn'-@T t er.i: 2 q c ~h ,,

t Y G l

_. . 1_ _ - ,

BELATED GORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGUIATORY CCFMISSION ,

BEFORE THE ATWIC SAFEIY AND LICENSING BOARD In the Matter of )

)

MEIROPOLITAN EDISON COMPANY, ) Docket No. 50-289 W '

) -

(Restart) //  %,

(Three Mile Island Nuclear ) c~-2 (.

Station, Unit No. 1) )

g  ;.:

y. . , = - , ,

{

WttONWEALTH'S RESEONSE TO i C:23 d Ca 02.r1 D:2qn C D ;)

AAFDDI INIERROGAIDRIES (FIRST SET) y W

T N l oi s\ G' >:

Answers of G. W. Fouse .

1. Provide location of milk sanpling, including distance and direction from 1MI. r

RESPONSE

i Data Attached. See Map Segment and identified naapling sites. .

3. Wat measures of radioactive materials do you take for animal' feed l and fodder?

RESPONSE t Sanples of animal feed and fodder were obtained from farms producing >

milk which was sanpled.

Sanples of milk, animal feed and fodder were obtained upon request by DER.

Respectfully submitted,

- '. [,'/Ab l. .

, C'h (t / g KARIN W. CARTER Assistant Attorney General Dated: March 19, 1980

. Nm CORaaSi%VDENo UNI'IED STATES OF AMIMICA i NUCLEAR REGUIAlORY CaHISSION BEFORE THE A'IDMIC SAFC1Y AND LICENSING BOARD

~

In the Matter of )

)

MEIROPOLITAN EDISON OCEPANY, ) Docket No. 50-289

) (Restart)

('Ihree Mile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF G. W. FOUSE Conmonwealth of Pennsylvania )

)

County of Dauphin )

G. W. EDUSE, being duly sworn according to law, deposes and says that he is Chief of the Division of Milk Sanitation, Pennsylvania Depart 2nent of Agriculture; and that the information contained in the Conmonwealth's Response to Aamodt Interrogatories (First Set) numbered 1 and 3 (for contention 4) is true and correct to the best of his knowledge, information and belief.

G. W. FOUSE Chief Division of Milk Sanitation PA Department of Agriculture Sworn to and subscribed  %

before me this day f*

• i S of March, 1980. 'e 'N ,'N

'w..

(Gj

~

j ' '),

y Notary Public Nl2'

- 3 6 e,,, m . , 3 ihi xI

~ s' *e.;1 N -l~ ,,, $

g 7. . . ,s

, O .oD h

BELATED. CORRESPONDENCh i

UNITED STATES OF AMERICA NUCLEAR REGUIAICRY CaNISSION BEFORE THE AICMIC SAFETY AND LICENSING BOARD In the Matter of )

)

FEIROPOLITAN EDISON COMPANY, ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

0}tDNWEALTH'S RESPONSE 10 m AAFDDr INIERROGAIORIES (FIRST SET) /f -

Answers of Margaret A. Reilly g CTJ'ma Contention 5 -

6-(lC' 'o n -'>- '.b CEF t.'th 6 ' ~ D-15A. Has it been considered to request farmers to remain?

% ~$~Wb 3 0 5" (!

a. Under what emergency conditions? N '

m -

b. khy?

RESPONSE ,

The question is not so nuch one of requesting farmers to stay, but one of permitting farmers to. stay to protect their investment.

Farners could be considered to be emergency workers in this context, and since they are presumed to be adult volunteers, they could be ,

permitted an exposure of 25 Rad whole body according to NCRP Report No. 39.

Contention 4 '

1. Provide locations of milk sanpling, including distance and '

direction from IMI.

a. Provide radiological milk sanpling data by location for 1974 until present.

RESPONSE

Docunents for sanpling locations and data will be sent to yoit under separate cover within two weeks.

t

b. Do you measure any other radioactive iodines in milk other than I-1317 .

(1) If so, what ones?

RESPONSE

Any radiciodine which is a gama emitter 'could be detected. These isotopes include fission products I-130 through I-135.  :

c. Do you measure any other radioactive naterials in milk?

(1) If so, identify.

l

RESPONSE

Any ganma emitter could be detected, theoretically. We specifically look. for Cesim 137, Barim 140 and Potassium 40. We also analyze for Strontim 90. .

t

2. What measures of raMnactive materials to you take for vegetables and fruit? t

a. How are vegetables and fruit selected for sanpling in terns of distance and direction from DE?

b. At what locations are these measurements made?

c. Provide data for 1974 until present. .

RESPONSE

Ue analyze vegetables annually for ganma emitters. They are sanpled at the nearest producer. The sanples are analyzed in our laboratory at Harrisburg. The requested data will be sent to you under separate cover within two weeks.

3. What measures of radioactive materials do you.take for animal feed and fodder?

a. Hoe are feed and fodder selected for sanpling in terms of l distance and direction from DII?

I i

b. At what locations dre these measurements made?

c. Provide data for 1974 tmtil present. i

RESPONSE

We do not sanple animal feeds on a routine basis.

Respectfully submitted,

./  ;

- TE i l. a c. l( E f )d' \

- i t, KARM W. CARnx Assistant Attorney General Dated: March 19, 1980 i

i i

i t

[

. RELATED CORRESPONDERE UNITED STATES OF AMERICA NUCLEAR REUIAIDRY COMISSION BEEDRE THE ATCHIC SAFE 1Y AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON 00MPANY, ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF MARGARET A. REILLY Conmonwealth of Pennsylvania )

)

County of Dauphin )

MARGARET A. REILLY, being duly sworn accordirg to law, deposes and says that she is Chief of the Division of' Environmental Radiation, Bureau of Radiation Protection, Pennsylvania Department of Enviretmeital Resources; and that the infonnation contained in the Ccmmnwealth's Response to Aarrodt Interrogatories (First Set) nunbered 1, 2, and 3 (for contention 4) and 15A (for contention 5)'is true and correct to the best of her knowluge, information and belief.

I~ s rf l

JJLQGW 7 MARGARETA.REJLLY ]'On b"/

Chief, Division of Environmental Radiation Bureau of Radiation Protection PA Department of Erwiretmeital Resources Sworn to and subscribed 1. -i before me this /fr/. day @ /

of March,1980.

g;

~ - 3:: 3 h .,%,y th .? )/) b <. ,

Notary Public h3' U,'.-- .

' c . ,, , ,

T , ;'l  ;

twv M. Cen5. !!et rr PcMe C -..

s Of-4'. R 'r/N'/ 1 m, commi.ica sci "a 2. i9t2 Hmisbwg, PA C::.f.ii Couty -

[p cc '

l

, l v O w

l 1

ggpx5R UNITED STATES OF AMERICA NUl1 EAR REGULATORY 0@t4ISSION BEFORE THE ATU4IC SAFEIY AIO LICENSING BOARD In the Matter of )

)

IEIROPOLITAN EDISON 034PANY, ) Docket No. 50-289 TI h,

) (Restart) Y A (Three Mile Island Nuclear ) Q,\ ,

Station, Unit No. 1) ) @ p

~

p~-:a. . ..

0@tMEALTH'S RESPONSE TO g 0 5c ef t':a sen

~

AAFOUT INIERROGATORIES (FIRST SET) N@ht MJ;;d

~ Dag Answers of Robert C. Furrer 0)

1. Regarding Department of Agriculture Plan Fixed Nuclear Facility Incident Plan, Appendix D of Annex E, Comuonwealth of Pennsylvania Pisaster Operation Plan (Limited Distribution Under Separate Cover).

a. Provide a copy?

RESPONSE

A copy has been provided to you on March 17 under separate cover.

b. Is this plan coupleted? If not, when is it forecasted to be coupleted?

RESPONSE

The draft plan is couplete; however, plans we periodically reviewed I

and subjected to refinement and, for this reason, it is initially published '

in draft form.  ;

c. To who is distribution limited?

\

RESPONSE

l Distribution is made to organizational elements of the Department of Agriculture and to agencies with responsibilities for responding to emergencies. See distribution list attached to the plan.

d. Has this plan been approved to ET ED?

RESPONSE

Copy furnished in March 1980.

e. Why is distribution limited? [

RESPONSE

As a normal cost control practice, copies are distributed on tla basis of apparent need.

f. Een was this plan requested to be prepared?

RESPONSE

Emergency response actions for nuclear incidents were in the form of standard operating procedures and elevated to the status of a formal plan -

l shortly after 'IMI based on PDR request. }

9

g. By whom was it requested to be prirnred?

RESPONSE

l Fennsylvania Emergency Management Agency.

h. How does your Emergency Plan interface with ET ED's emergency plans?

RESPONSE

'Ibe Agriculture Plan is an element of the Conmonwealth's Plan and the question of interface should be related to the broader Connonwealth Plan.

Ita interface is one of cooperation.

i

l l

l

3. Was there any request ude of you by MEr ED or their agents on January 31 or to this date for a copy of the plan referred to in Question 1 to be sent to m ? ,

RESPONSE -

March 5,1980, MET ED representative called Agriculture and stated he had a copy of the <.amde interrogatories. Since Agriculture had a copy of the interrogatories, the representative was advised that a copy of the i plan would be sent to Ms. M. Aamdt and to MEr ED.

f.

b. If so, nam the person who made the requent.

RESPONSE

i Mr. George Giangi.

4. Provide priorly existing plan, if any, that plan of Annex E replaces.

RESPONSE

Copy of August 1979 memrandum (plan) has been sent to you on March l 17 under separate cover. ,

12. Are there criter'.a for deciding for an evacuation of livestock? If i so, what are they? If no, why not? .

RESPONSE

Priority is of necessity, given to the protection of htrnan life. The resistance of livestock to the effects of radiation is greater than that ,

of hunans and, therefore to maintain a livestock population in a zone where l

precautionary evacuation has taken place is entirely possible. (Annex B to Agriculture Plan.)

i

13. How nuckt time is needed for evacuation of livestock in a ten-mile area of IMI?

RESPONSE

The Agriculture Department has no data upon which to base a time estimate for evacuation.

14. What will be done to assist and/or protect any farmer who chooses to remain? ,

RESPONSE

Farmers choosing to romain are advised to contact the County Emergency Management Agency and their County Agent to report their status. ,

Radiation advisories will be issued.

15A. Has it been considered to request farmers to remain? t

RESPONSE

No.  !

i 16A. Has any provision been made for. acceptance and care of livestock at distant points?

RESPONSE ,

No.

15B. Would the economic structure of the farm tend to cause him to remain?

RESPONSE

The Agriculture Department has no data and is unaware of other data sources,to respond to this question.

}

15C. Are there any conditions of general emergency and evacuation ordered  !

where farmers would be advised to remain longer than the general public?

. RESPONSE None. Precautionary evacuation recommendations to the public would  !

apply to everyone in the emergency zone.

16B. If livestock needed to remain out of the IMI area for a considerable period of time, have any means been considered for relocating farmers  ;

and their families? '

RESPONSE

No. The problem of relocation would include the entire population -

evacuated.

19. Did you' consider on March 28, 1979 or anytime thereaft- to evacuate livestock in the 'IMI area?

RESPONSE ,

Evacuation of livestock as a precautionary action was considered and rejected based on the contamination levels found in forage sanples and the  :

fact that priority for evacuation was to protect hunan life and evacuation of livestock was not considered possible.

20. Have you ever considered the evacuation of livestock? -

RESPONSE ,

Yes, as noted in response to Interrogatory No. 19.

21. To the best of your knowledge, is there any known means of generating  :

electricity other than nuclear power that has elicited consideration ,

of or initiated planning of evacuation of livestock?  ;

f

~.

I

RESPONSE

i The Department has no data and is unaware of other data sources to respond to this question. '

Respectfully submitted, i t a v /(. .]- (L A O N -

FARM W. CARTER Assistant Attorney General Dated: March 19, 1980 s

s F

L t

l e

s i

e e 6 e

b d

UNITED STATES OF AMERICA NUCEAR REGUIATORY 00tESSION  ;

BEFORE THE ATQ4IC SAFELY AND LICENSING BOARD In the Matter of 4

)

)

ME*IR0l'OLITAN EDISON 03fANY, ) Docket No. 50-289  ;

) (Restart)  :

(Three Mile Island Nuclear ) i Station, Unit No. 1) ) l AFFIDAVIT OF ROBERT C. FURRER  !

0:xmonwealth of Pennsylvania )

) ,

County of Dauphin -

)

ROBERT C. FURRER, being duly sworn according to law, deposes and says that he is Management Analyst, Bureau of Adninistrative Services, i

Pennsylvania Department of Agriculture; and that the information contained j in the Conmonwealth's Response to Aamodt Interrogatories (First Set)  !

ntmbered 1, 3, 4, 12, 13, 14', 15A, 16A, ISB, 15C, 16B, 19, 20, and 21 (all for Contention 5) is true and correct to the best of his knowledge, information and belief.

ekv'? 24W9 ROBERT C. FURRER Management Analyst .

Bureau of Administrative Services PA Department of Agriculture Sworn to and subscribed

. before me this /#fday  ;

of March, 1980.

'! ' by-t.J h b or:stic' i

E' -

~

Notary Public s C:ry ? "~:.: ". ? *gbrg

~

liv C' cs'r, L.ra i.'... 2?. I'02 1:da:kr!. ii. D.t;<.ir. (cur.ty ,

e v ~ ,

" ""'* *""0Nna w .

UNITED STATES OF AMERICA NUCEAR REGUIATORY 00 MISSION BEFORE TIE ATQEC SAFE 1Y AND LICENSING BOARD In the Matter of )

) <

FEIROPOLITAN EDISON CQfANY, )

) Docket No. 50-289 (Three Mile Island Nuclear ) (Restart)

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify diat copies of the Camonwealth of Pennsylvania's Response to Aamodt Interrogatories (First Set) were served upon those persons on the attached Service List by deposit in the thited States Inail, postage prepaid, this 19th day of March, 1980.

g Qt. b(I -

d. 't)

ARIN W. CARTER Assistant Attorney General W ~

Dated: March 19, 1980 '/ d,%

c r. r-

8. '

.0

e.nc7 :3 c.

6" oment t.h s:: req 2) h d q : 1 Sir.i:a

% ' & g '/'

N q ,,/

l

{

. gxuu: maazwosD2:w.  :

UTITED STA'IES OF AMERICA ,8 -

i WCLEAR REGEATORY CCitfISSION

[% ,

i BERRE THE ATOUC SAFEIY AND LICENSING BOARD (p/. ,N y.

[" ~ ' "  :

In the Matter of

~~

> ?-- ;

)

MEIROPOLITAN EDISON CCHPANY,

)

)

h6 @""~'g~G,24 i p :c /Q '

Q,

) Docket No. 50-289 G ^

\g  !

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

) (Restart) /v .,

) ,

i f

SERVICE LIST George F. Trowbridge, Esquire Theodore A. Adler, Esquire l Shaw, Pittman, Potts & Trowbridge Widoff, Reager, Selkowitz & Adler ,

1800 M Street, N.W. P. O. Box 1547 Washington, D.C. 20006 ,

, Harrisburg, Pennsylvania 17105 Ms. Marjorie M. Aamodt Ivan W. Smith, Esquire

• R.D. #5 Ch=4 man Coatesville, Pennsylvania 19320 Atomic Safety and Licensing Board Panel ;

U.S. Nuclear Regulatory em miesion  !

Ms. Holly S. Keck, leg. Ch=4 man Washington, D.C. 20555 i Anti-Nuclear Group ReprasanHng i York (ANGRY) Dr. W lter H. Jordan  ;

245 W. Ph41=dalphia Street Armic Safety and Licensing Board Panel .

York, Pennsylvania 17404 881 W st Outer Drive l Oak Ridge, Tennessee 37830  :

Ms. Frieda Berryhill, Ch=4 man (

Coalition for Nuclear Power Dr. Linda W. Little l Plant Postpnn = t Atomic Safety and Licensing Board Panel l 2610 Grendon Drive 5000 Hermitage Drive I W41=fngton, Delaware 19808 Rala4gh, North Carolina 27612 Mr. Robert Q. Pollard Docketing and Service Section  !

609 Montpelier Street Office of the Secretary Balitmore, Maryland 21218 U.S. Nuclear Regulatory Cm =4=sion i Eshington, D.C. 20555 i Walter W. Cohen, Esquire Consumer Advocate Ellyn R. Weiss Dep-=it of Justice Sheldon, Harmon, Rof man & Weiss Strawberry Square, 14th Floor 1725 I Street, N.W.

Harrisburg, Pennsylvania 17127 Suite 506 Washington, D.C. 20006 Dr. Chauncey Kepford Judith H..Johnsrud Karin P. Shaldnn, Esq. (PANE)

Envi u n 1 Coalition on Nuclear Sheldon, Harmon, Roiman & Weiss Power 1725 I Street, N.W. , Suite 5%

433 Orlando Avenue Wshington, D.C. 20006

. State College, Pennsylvania 16801 James A. Tourtellotte, Esquire Mr. Steven C. Sholly Office of the WHve Ingal 304 South Market Street Director Mechanicsburg, Pennsylvania 17055- U.S. Nuclear Regulatory Cm=4=sion E shington, D.C. 20555

I John A,i Iavin, Esquire Jordan D. Omningh==, Esquire Assistanr Couthel Attorney for Newberry Township  ;

Pennsylvania Public Utility T.M.I. Steering Comnittee  ;

canniasion 2320 North - W Street i P.O. Box 3265 Harrisburg, Pennsylvania 17110  ;

Harrisburg, Pennsylvania 17120 Marvin I. Iawis l Robert L. Knupp, Esquire 6504 Bradford Terrace  !

Assistant Solicitor Philadelphia, Pennsylvania 19149 l Comty of hehin ,

P.O. Box P Jane lee l 407 North Front Street R.D. 3, Box 3521 Harrisburg, PA 17108 Etters, Pennsylvania 17319  ;

John E. Minnich '

l Chaiman, Dauphin County Board of CM =iasioners Dauphin County Courthouse  ;

Front and Market Streets '

Harrisburg, Pennsylvania 17101  !

i i

~+

f e- .

m

~ '

.. l j

h i

l-

+

+

i i  !

i i

i

_