ML19257C116

Ack Receipt of 800106 Interrogatories to Intervenor People Against Nuclear Energy Re Psychological Distress Contentions.Intervenor Will Not Respond Until NRC or ASLB Formally Admits Contentions for Discovery

ML19257C116
Person / Time
Site:	Three Mile Island
Issue date:	01/15/1980
From:	Jordan W SHELDON, HARMON & WEISS
To:	Lewis M AFFILIATION NOT ASSIGNED
References
NUDOCS 8001240551
Download: ML19257C116 (2)

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K ARIN P SHELOON WASHINGTON,D.C.CoooG v202[Es 70 G AIL M. HARMON E LLY N R. WEISS WILLI AM S JORDAN, til g SIN ,

A N N E LU Z Z ATTO January 15, 1980 #

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Mr. Marvin I. Lewis  % -M

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6504 Bradford Terrace g E-Philadelphia, Pennsylvania 19149 .

Dear Mr. Lewis:

As Counsel for PANE, we have received your interroga-tories dated January 6, 1980, in which you pose three questions to intervenors raising psychological distress contentions. As you know, neither the Licensing Board nor the Commission has yet ruled on whether these contentions will be considered. For that reason, these contentions are not yet subject to formal discovery.

You refer to page 19 of the Board's Order of -December 18, 1979, as indicating that discovery is to proceed as if the psychological distress contentions had been admitted. As I read it, the language on page 19 refers only to contentions in-volving the post-accident generation of combustible gas. The proceeding paragraph contains the only reference to psychologi-cal distress contentions, and it states only that rulings on those contentions have been deferred.

We have already informed the NRC Staff that we do not intend to respond to formal discovery requests until after the psychological distress issue has been admitted, and we will be consistent in that practice. However, I will be glad to confer with you informally concerning your interrogatories and any other questions you may have.

Sincerely, A W [.7' k ^. M<

William S. Jordan, III C' T o WSJ/dds e.: ,

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1796 019 8001240 .

UNITED STATES OF AMERICA * * *U NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, et al., ) (Restart)

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(Three Mile Island )

Nuclear Station, Unit )

No. 1) )

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CERTIFICATE OF SERVICE I hereby certify that a copy of the attached letter was mailed postage prepaid this 15th day of January, 1980, to the following:

Secretary of the Commission ATTN: Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan 881 W. Outer Drive -f Oak Ridge, Tennessee 37830 '

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Dr. Linda W. Little 5000 Hermitage Drive Raleigh, North Carolina 27612 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 "M" Street, N.W.

Washington, D.C. 20006 CD James Tourtellotte, Esquire 04 Office of the Executive Legal Director CC)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 [f,

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. - - cN . &wdsSc William Sf Jordan ,' III