ML19312D789
| ML19312D789 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/11/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Lewis M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8003250335 | |
| Download: ML19312D789 (6) | |
Text
ar 9
s**ECyg y
Io UNITED STATES g
y
> r, g
NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D. C. 20555
.f
\\.',',',. #
March 11, 1980 Mr. Marvin I. Lewis 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 In the Matter of METROPOLITAN EDIS0N COMPANY, ET AL.
(Three Mile Island Unit 1)
Docket No. 50-289
Dear Mr. Lewis:
I am in receipt of your fourth set of interrogatories and discovery requests to the HRC Staff and your pleading entitled, "Intervenor Lewis's Special Problem with Receiving NRC Mailings and Suggestions for Relief". To save time and avoid confusion I am answering some of your questions now. The responses to your interrogatories will be filed as soon as possible.
First, your discovery request for NRC Translation 628 in the original Japanese, Regulatory Guide 1.52, and ANSI 510-1975 has been forwarded to Jona Souder, Chief of tne Local Public Document Room Branch. She will be in touch with you.
Second, you ask that Susan Barley be sent a copy of the Rogovin Report. We cannot comply with this request. Each intervenor is entitled to one copy of the documents the NRC Staff sends as a convenience to the parties. As you indicated, you have already received your copy.
Third, you supplied us with Ms. Barley's address so that her name could be added to "the Staff's mailing list in this docket..." At the Pre-hearing Conference which Ms. Barley attended, the Staff was not asked to, and the Board did not order anyone to place Ms. Barley on our service list. We did agree to send her copies of communications between you and the Staff.
I have enclosed the pages of the transcript where this was discussed (Tr.1565-67). We have and will continue to send Ms. Barley copies of letters, answers to interrogatories, and other correspondence we have with you.
l 800ssso 3 %
G
)
Mr. Marvin I. Lewis Finally, in your." Suggestions for Relief" you asked the Staff to place mail addressed to you in a United States mailbox. Where possible, the Staff will fulfill this request.
Sincerely, g did X
x' 4.6dl 0[
8 Lucinda. Low Swartz Counsel for NRC Staff Enclosure as stated cc w/ enclosure:
Ivan W. Smith, Esq. Chairman.
Or. Walter H. Jordan Dr. Linda W. Little Susan R. Barley
f p
puzz.%
1509 i
l on my right.
i 2
MS. SMITH:
Patricia Smith, Newberry Township.
l MR. BROOKS: Stephen Brooks, ANGRY.
}
MR. KONKLE:
Don Konkle, PANE.
A J
MS. BARLEY:
Point of information.
Mr. Lewis isn't 6
here today, but 7
CHAIRMAN SMITH:
You're Ms. Barley?
~
l g
MS. BARLEY:
Right.
I i
9 CHAIRMAN SMITH:
Yes, Ms. Barley, there is a problem
- g under our rules --
i, MS. BARLEY:
That is what I wanted to know.
33 CHAIRMAN SMITH:
-- however, we -- I am sure we can i
work around it so: e way for the purpose of your taking Mr.
1
- 3
(
7, Lewis ' place.
I Those who are parties to the proceeding, I believe i
.4 I
we're going to have to from time-to-time come to the table,
(
.i f4 so, could you move to the front row and I'll ask anybody who l
- 7 is in the front row who is not a participant in the proceeding, 7,
g ;9 if they will allow the parties to have enough room.
3 Mr. Konkle?
l.
,_.1
-)
MR. KONKLE:
Konkle.
l 7
CHAIRMAN SMITH:
How do you spell your name?
a MR. KCNE*.Z :
K-c.-k-i-9.
CHAIRMAN SMITH:
Mrs. Aamodt is not here.
..4 i
4 Who is representing ANGRY?
l 8
1 l
i 4
I
- e csas na,,me=
q I
l extend. autobiographical in nature, and I would certainly con,
l l
}
cur with what Mr.1.dler was saying, that it seems rather 2.
i i
incongruous that counsel for the suspended licensee uants to 2
accelerate this proceeding as*much as possfble and at the j
same time tries to hamstring as much as possible participa-3 tion by the intervenors.
e t
)
I simply don't understand what's going on.
- Well, maybe I do, but I don't think the publia interest is being 8
i l
served with this attitude.
t 9
I I
Thank you, Mr. Chairman.
10 I
I I
i CHAIRMAN SMITH:
Ms. Smith, do you have a comment i
11 I
to make for Newberry?
l 12
_. i l }
MS. S::I!H: Yes, sir.
Attornef Cunningham.dces 13 l
}
request retraction.
His suggestion would be May 16th.
14 CHAISDGdi SMITH:
Ms. Earley, are you aware of 12 Mr. Lewis' prendse with respect to discovery?
14 MS. BARLEY:
Yes, I am very well aware of that.
17 For example, number one, I am supposed to be helping, la
-i l
and I am trying like hell to help, but this moot question l's 19 probably totally out of order, but is there some way I can
- 0 get on a limited distribution 1ist of whatever communications 21
.I between the Board and the Mr. Lewis, the licensee and Mr. Lewis.
the staff and Mr. Lewis, so that -- I got his licensee
!t responses to the fir:: 22: ef interr:; :crias.
- ._. ' u.:,
l I4 l
"All documents in reference in the discovery reading room 3
I.,.
r_._= _v.. % =_ic
(
j La a-#
iW 1566
- I coag m l
I or will be placed there shortly."
He lives 90 miles away.
I l
He has a full-time job and is on different g
f shifts.
I have l
a full-time job.
I can get there, but it's very hard --
I
(
CHAIRMAN SMITH:
Stop for a cment.
Maybe we can I
shortcut the process.
Do you !} ave any ob;ections to adding Ms. Earley to the service list?
To your service list?
She 7
l would, after all, have clearly been qualified as an interveno$
had she -- as a matter of fact, she can still file a petition.
8 i
t 1
MR. TROWBRIDGE:
Is the Chair =an's list on matters j
t i
between us and Mr. Lewis.
10 l
That is, Mr. Lewis, as you recall, j 4
1 is a very limited participant.
o CHAIRMAN SMITH:
I understand.
12 I
l MR. TRCWBRIDGE:
For the moment, really trying to i
1 f3
.I clarify what I'm being asked.
To put Ms. Barley on the
'1 I4 mailing list of matters between us and Mr. :4vis?
~
MS. BARLEY:
Between Sr. Lewis and the staff.
id I
MR. TRCWBRIDGE: Am I being asked to --
{
17 1
CHAIRMAN SMITH:
The Board has no pr:blem, we can i
18 i
1 simply add Barley to the Secretary's service list, but we 19 can't add it to yours nor the staff's.
I am si: ply asking 1
if, in the interest of accelera' ting Mr. Lewis' discovery
{
,1 problems, would you object to adding Ms. Barley?
l i
'.e
^
i MR. '.'ROWBRIDGE :
And I'm seeking clar:.firation --
l 22 i
f I
li matters in which involve ec=munications to and fren Mr. Lovis.'
that is, if we have a discovery request to Mr. Lewis, we put DTD
- D ~@~Y $'
0 inre
=v
,x gJ o
. lln.a
=am. m..m
.s.
.se m.. a..a w
.w
,,. w.u. m ; w. n..
occ ^yx-
' ~ m p ri T n ' ": w m
~
~
i p
i maar.m 1*c7 l
l l
Ms. Barley on?
i j
CHAIRMAN SMITH:
Is that what you're asking for?
2 1
{
MS. BARLEY:
Right.
2 Whatever the communications I
between Mr. Lewis and licensee, could I please also have a i
copy of it?
i 2.
j MR. TRCWBRIDGE:
5 I have no prorlem with that.
I don't think you meant to add Ms. Barley to the list for all 7
}
documents in the entire proceeding.
S CHAIRMAN SMITH:
Sure; thank you.
9 4
Mr. Tourtellotte, could you accom.nodate that inter-10 venor in that fashion?
11 MR. TOURTELLOTTE:
Yes.
i 12 k
l CHAIFbGS SMITH:
Okay.
Have you concluded your 13 I
points then?
14 l
l MS. BARLEY:
My address?
13 MR. TOURTELLOTTE:
We have your address already,
!d thank you.
17 1
l MS. BARLEY:
Okay, that was sort of a side issue.
9 i
k j
I talked to Mr.
Lewis, and I would say he concurs e
I with Mr. Adler, Dr. Kepford, in that -- Newberry also --
i in that he.would like an extension for response and request 21 L;
for the three months this seems to be --
6 j
CHAIRMAN SMITH:
And.it's your understanding that i
I he needs one?
. i 24 MS. BARLEY:
Oh, yes, because the same problem he's.
IS having, responses from licensee, is the reference to documents l M M Y N Rw
!N a,e sm,Tw Camfeb TTweTP t e marrt '97
.=
_.__