ML19305C537

Statement Re Intervenor Special Problem W/Receiving NRC Mailings.Suggests Relief by Placing Mail in Public Post Box W/O Using NRC Internal Mailing Apparatus

ML19305C537
Person / Time
Site:	Three Mile Island
Issue date:	02/27/1980
From:	Lewis M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19305C535	List: ML19305C534 ML19305C537 ML19305C549
References
NUDOCS 8003310029
Download: ML19305C537 (2)

Text

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UNITED STATES OF El. ERICA NUCLEAR REGULATOaY COE.ISSION. RDTED CORRESPONDg l] BEFORE THE ATOMIC SAFETY AKD LICENSING 30ARD.

Inthe matter -f  ; t- g METROPOLITAN EDISGN CO:.".PANY I DOCKET No. 50-289 #

(Three Mile Island , Unit L) p %Tro

.I "*%c 9 l -- Fgg 2 -

77 INTERVENOR LEWIS'S SPECAIL PROBLE" WITH RECEIVEING NBOWA155Cg EdQ 4 AND SUGGESTIONS 70R RELIEP. II (f4 N

NRC rules (2 art 2 Para 2.710 ) and the Eard'e rulings in . e '

Docket have assumed that 5 days for mail service is adequate.

Intervenor Lewis assumed likewise. Hail service from most -

parties has run five days or less.

There is one notable exception.

NRC mailings from the Staff to Intervenor Lewis speaifically on this Docket have been running consistently longer than 5 days.

i Letter Lucinda Low Swartz to Lewis dated 2-6-80 received 2-14-80. '

collins to Arnold "

2-11 "

2-19 (2 letters),

Eisenhtit to All Lic " 1-29 a 2-15 Varg to All Eds " 1-24 O s'o u-MA iv ;;aAmt. O n H3

" 2-19 .

Normally, the 3oard should not be troubled with the minort.11 scheduling difficulties experienced by the US Mail. However, There is a pattern here that puts Intervenor Lewis at a specall disadvantage arfd thereby limits effective participation.

First , mailings from the Licensee generally tale only 4 days '

s to arrive. No Licensee mailings have taken over 5 days. Mailings from other intervenors have only taken one or two days.

CEA's Motion To Permit Oral Argument was mailed on the 15th and 1 arrived on the 19th.

Intervenor Lewis tried the following experiment.  !

While in D.C. to attend the PR 50, 51 ilaste Confidence Hearings at 1717 H St , Intervenor Lewis mailed several items from the Post Sox at the corner. One of these letters was addressed to himself. Upon returning to his residence 3 days later , the "

i letter was awaiting him.

1 q

l This leads me to believe that the problem with the slow delivery 1 of NRC Staff communications to Intervenor Lewis is due to internal ]

handling problems within the NRC.

8003 3100M The Relief which Intervenor Lewis seeks is that the 3oard directs

~

9 2

Poet box and not use the NRC internal mailing apparatus, n

Intervenor Lewis seeks this specall releif

' because of the following specall circumstances:

1. Intervenor Lewis is far from the LPDR and the other repositories in the Harrisburg and D.C. areas and must make specall arrangements to survey any documentsimentiondd in the Staff's submittals.

2. Intervenor Lewis's Associate * , Susan Earley, is without a car , temporarily,and works a full time job. Coupling this situation with the curtailment of operating hours at the Licensee's Discovery Rearkng Room, Intervenor Lewis has a very specall problem in researching documents in -

the Harrisburg/T:4I area which is only exacerbated by slow mail delivery.

3. The letters, Collins to Arnold dated 2-19-80 and the letter, Eisenhut to a11 power reactor licensees dated 1-29-80 , are subjects of interrogatories on the Lewis Contention. Ifthe Board hadn't extended the time for filing interrogatories, the above mentioned letters would have arrived too late to aid in providing an adequate record.

Ms Earley reported to Intervenor Lewis that Objections to Items previous to the Prehearing Conference could be objected to until 25 Feb 1980. Intervenor Lewis requests that the Efbdconsidertheaboveatimelyfiling csnsidering the Boardh Statemen'ts at the Prehea"ing Conference on 2-13-80.

• Intervenor Lewis has fashioned Ms Earley's aid in these proceedings by referring to her as his Associate. The word , e-ssociate, has caused some confusion. Intervenor Lewis used the term , Associate , to mean "a colleague , joined in duty and purpose." The word , associate , does not refer to any degree or profession in common useage.

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