ML19260C552

Forwards Licensee Response to Intervenor TMI Alert First Set of Interrogatories

ML19260C552
Person / Time
Site:	Three Mile Island
Issue date:	12/19/1979
From:	Zahler R SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Adler T WIDOFF, REAGER, SELKOWITZ & ADLER
Shared Package
ML19260C553	List: ML19260C552 ML19260C554
References
NUDOCS 8001070490
Download: ML19260C552 (2)

Text

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December 19, 1979 Theodore A. Adler, Esquire Widoff, Reager, Selkowitz & Adler Post Office Box 1547 Harrisburg, Pennsylvania 17105 Re: Three Mile Island Unit 1 Docket No. 50-289 (Restart)

Dear Ted:

I enclose Licensee's response to TMIA's first set of interroga-tories which were served on November 30, 1979. As was indicated in Mr. Trowbridge's letter to you of December 7, 1979, our response at this time is limited to TMIA contentions 5 and 7 to which we have not objected.

Although the TMIA document was labeled " interrogatories," the requests were in some cases interrogatories, and in others, document requests. As to those which were document requests, such as 27(b),

35(c), 38(d), 40(b) & (c), 52(c), 54(b) and 56(b), they have been treated as such by counsel. Documents sought in these numbered requests, as well as all documents referenced or described in responses to other interrogatories, will be available in Licensee's Discovery Reading Room by January 2, 1980. There are two exceptions to this general approach we are taking to the availability of documents. First, the documents specifically identified by file number in response to Interrogatory 40 are to be found in NRC's document rooms in Washington, D.C. and in Harrisburg, Pennsylvania. Second, the " Job Ticket" files referenced in Interrogatory 33 and elsewhere comprise some 40,000 documents, many of which are voluminous, which we have not copied and placed in the Reading Room; the Job Ticket files will, however, be made available for TMTA's inspection at the Discovery Room upon five working days' notice to either Mr. Zahler (202) 331-4100T or Mr. Wilson (717) 944-9793).

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SHAW, PITTMAN, POTTS & TROWBRIDGE Theodore A. auter, Esquire December 19, 1979 Page Two In instances where the date or period of interest was apparent, the response is so directed. Where, however, no date or period was provided, we have assumed a date or period, such as the entire operat~

ing period for Unit 1 and Unit 2 of TMI in the response to Interroga-tory 25.

We have provided through the responses and the documents virtually all the information sought. However, we have not provided responses where we view the requested information as objectionable. Thus, we have not provided individual telephone numbers for persons because we regard such requests as improper, and we require that TMIA make any requests through counsel to contact individual Licensee employees. We have not provided responses to your requests in Interrogatories 26 and 27 to the extent they seek all oral instructions or orders, because to do so would be impossible, impractical and oppressive. We have not provided responses to Interrogatories 31 and 32 which we regard as clearly outside the scope of TMIA Contention 5. To the extent similarly unrelated information in other interrogatories may be interpreted by TMIA as having been sought, we have not provided it for the same reason.

Finally, we regard your statement that "these interrogatories are deemed to be continuing, and shall be supplemented by Licensee when and if additional or corrective information is obtained" as requiring that we comply with Section 2.740(e) of the Commission's Rules of Practice.

We intent eo comply with that regulation.

Sincerely yours, Robert E. Zahl A

Counsel for Licensee REZ:clb cc: Service List i694 0012