ML18045A205

Discovery Rept Per ASLB 800229 Order.Served Interrogatories & Request to Produce Documents on Nrc.Initiated 800319 FOIA Request.Will File Motion to Compel NRC Responses to Certain Interrogatories & Documents.Related Correspondence

ML18045A205
Person / Time
Site:	Palisades
Issue date:	04/25/1980
From:	Murphy P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:
References
NUDOCS 8006060465
Download: ML18045A205 (3)

Text

ISHAM, LINCOLN & BEALE COUNSELORS AT LAW ONE: f"IRST NATIONAL PLAZA FORTY*SE:CONO F"LOOR CHICAGO, ILLINOIS 60603 TE:LE:f'HONE: 312-ssa-7500 TE:i..E:.C 2-s2aa WASHINGTON OF"F"ICE:

1120 CONNE:CTICUT AVE:NUC:. N. W.

SUITC: 325 WASHINGTON, D. C. 20036 202*633*9730 April 25, 1980 In the Matter of )

) Docket No. 50-255 CONSUMERS POWER COMPANY ) License .. No. DPR-20 (Palisades Nuclear Power Facility) )

To: Honorable Ivan w. Smith DOCKETED Administrative Law Judge USNRC Atomic Safety and Licensing Board APR 2 91980""'

United States Nuclear Regulatory Commission Office of the Se~

O~keting&~

Washington, D.C. 20555 I'ranch ~

Dear Judge Smith:

The purpose of this letter is to provide you with a report* on the status of discovery and other prehearing events in this cause pursuant to your Memorandum and Order dated February 29, 1980. Counsel for the NRC Staff and Licensee have discussed and agreed to the contents of this letter.

1. DISCOVERY INITIATED BY LICENSEE Licensee served interrogatories and request to

• produce documents on the NRC Staff on February 25, 1980. In addition, Licensee initiated a Freedom of Information Act request on March 19, 1980. The Staff responded to Licensee's discovery on March 31, 1980, and April 15, 1980, by which some interrogatories were answered and some requested docu-ments were provided. The Staff also indicated that addi-tional documents would be provided in response to the Free-dom of Information Act request. The Staff has also objected to some of Licensee's interrogatories and document requests.

The Staff has not responded to the Freedom of Information Act request as of this date, but is continuing to collect the documents requested. Licensee will file, on or about

Hon. Ivan w. Smith Page Two April 25, 1980 May 7, 1980, a motion to compel responses by the Staff to such interrogatories and document requests for which Licensee believes the Staff's objections are not meritorious.

2. DISCOVERY INITIATED BY STAFF On April 18, 1980, the Staff served interrogatories and request for the production of documents on Licensee.

Responses to these requests are due in the latter half of .

May 1980. Licensee is collecting the requested materials.

Respectfully submitted,

. . . /'"') . .n ."\

. / ,.~ \ i,! l\ ; ; t*i.... /

() c.'t.:.~. -'// .. *_ .' f, .:~,:* 1-/*~t~ ~.

Paul M. Murphy*** '

One of the Attorneys for consumers Power Company PMM/sag cc: All parties on attached service list

... ~. -

Honorable Ivan w. Smith Administrative Law Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel u.s. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 James P. Murray, Esq. _ Atomic Safety and Licensing Director and Chief Counsel Appeal Board Panel Rulemaking and Enforcement Division U.S. Nuclear Regulatory Commission Office of Executive Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James Lieberman, Esq. Judd L. Bacon, Esq.

u.s. Nuclear Regulatory Commission Consumers Power Company Office of Executive Legal Director 212 West Michigan Avenue Washington, D.C. 20555 Jackson, Michigan '49201 Stephen G. Burns, Esq. . .

u.s. Nuclear Regulatory Commission Office of Executive Legal Director Washington, D.C. 20555 Docketing and Service Section Office of the Secretary u.s. Nuclear Regulatory Commission Washington, D.C. 20555