ML19305C534

Statement Re Communication W/Nrc Re Mailings & Related Problems.Offers Acceptance of NRC Answers to Second Set of Interrogatories on 800225 Provided That Objections Be Communicated to Intervenor by Telcon

ML19305C534
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 8003310027
Download: ML19305C534 (2)

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UNITED STATES OP in n20A WTED CORRESPMDE

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NUCLEAR REGULATORY CCMMISSION t-

• c, rEFORE THE ATClaIC SAPETY AND LIC3HSING ECARD. s In the matter of g3 g  %

METROPCLITAN EDISOU COMPANY

- Docket No. 50-259d (Three Mile Island , Unit 1.) 7 FEB 2 71980 >

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h cmce of Be Sumh4 Docketing & Sgylce Intervenor Lewis Communication with Staff concerning

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NRC MAILINGS ABD RELATED PRCELHdS.

The letter , Lucinda Low Swartz to Marvin I. Lewis dated 46,80, was received by Intervenor Lewis on 2-14-80. Normally , a slowdown in 3RC mailings of 9 days would only be a minor inconvenience.

• However, in this case due to the Timing of a Specall Prehearing Conference, the issues raised in your letter could not be raised at the Specail Prehearing Conference. Further , the SPHC was the appropriate forum in which to raise these issues. Even more , my associate, Ms Earley ,was at the SPEC and empowered to speak for me.

The first point in your Feb 6 letter is a notification : hat the answer to Lewi's's Second Set of Interrogatories will not follow the schedule demand &d by the rules for the other parties. Further, there .'a a disclaimer that the Staff need not follow the schedule.

Es Swartz states that the reason that she cannot answer within the time .1mits set for other parties is that the questions are 1 quite lengthy. .

Intervenor Lewis does not believe that the Second det of Inter-

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rogatories are quite lengthy. There are only 10 questions. The length is not due to the questions , but due to the background information included for clarification.

Nonetheless, Intervenor Lewis can accept answers to his Second Set of Interrogatories on 25 Feb with the following proviso"s :

1. Due to slow NRC mails, an KRC staffer shall place the envelop containing the ansvrers in a public mail box or Post Office and sign his name, place of deposit, and time on the outside of the envelop.

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If any interrogatories will be objected to by the Staff, said objectionc will be communicated by telephone to Intervenor Lewis at 215 CU 95964 or Susan Earley at 717 533 65h6 upon receipt of this Communication.

3. Answers to interrogatories will be responsive.

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Another point i Swartz lotter of 80.2.6 requires correcting'.

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Since Ms Swartz a matter of record, even minor points require correction to provide as accurate and flawless a record as possible.

Ms Swartz Starts the second paragarh in her letter,"I received a note from you today asking..." and ends the letter with," I regret that you rushed to such a hasty conclusion."

Intervenor Lewis has consulted several d.tctionaries and a thesaurus.

Howhere, no way is asking a synonym for concluding or conclusion.

Intervenor Lewis asked; he did not conclude.

Intervenor Lewis regrets that Xs Swartz , a graduate lawyer, does not apppeciate the subtle difference between asking and concluding. .

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E NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

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h. February 6,1980 '"

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Marvin I. Lewis 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 In the Matter of Metropolitan Edison Company, et al .

< (Three Mile Island, Unit 1)

Docket No. 50-289

Dear Mr. Lewis :

We have received your second set of interrogatories to the NRC Staff and are in the process of responding to them. The regulations do not set a time period within which the Staff must answer interrogatories although we do try to respond within the period set for other parties. In this case, however, your ues-tions_are February 25D, 80.- quite, lengthy and we will be unable to answer them until

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I also received a note from you toda asking whether Ann Tipton who works for ~

the NRC Office of Executive Legal Dire was also the Ann Tipton who wrote to the Commission concerning the restart of TMI-1. These women are different people and coincidentally share a name. I regret that you rushed to such a hasty conclusion.

• Sincerely, l n

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L0Y $ U N D-R r

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• Lucinda Low Swartz .-

h Coonsel for NRC Staff t m .._