ML19209C339

Response to Intervenor Skagitonians Concerned About Nuclear Power 790821 Interrogatories.Interrogatories Are Untimely & Relate to Matters on Which Record Has Been Closed. Certificate of Svc Encl

ML19209C339
Person / Time
Site:	Skagit
Issue date:	08/27/1979
From:	Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO.
To:
References
NUDOCS 7910150097
Download: ML19209C339 (4)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

. )

PUGET SOUND POWER & LIGHT ) Docket Nos. 50-522 COMPANY, et al., ) 50-523

.)

(Skagit Nuclear Power Project )

Units 1 and 2) .) August 27, 1979

)

APPLICANTS' RESPONSE TO INTERVENOR SCANP'S INTERROGATORIES TO APPLICANT DATED AUGUST 21, 1979 On August 21, 1979, Intervenor SCANP served certain interrogatories and requests for production to Applicant Puget Sound Power & Light Company and its attorneys.

These interrogatories and requests seek information concerning plant water systems, including blow down flow, the circulating water system, and the make-up water sys-tem. Applicants' object to these interrogatories and requests on the ground that they are untimely. They were not served by the June 1, 1979 deadline for initial dis-covery requests that was fixed at the April 24, 1979 con-ference. Tr. 11, 94C-949. Furthermore, it chey relate s1 any matter in controversy in this proceeding, w;.ich Applicants deny, they could only relate to matters on which the record has been closed aad on which proposed findings of fact are under preputation and soon t5 be submitted. They are thus untimely on this additional 1146 084 7 910150 C i]

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4' ground. Finally, Applicants object to these interrogatories and requests on the additional ground that the information sought falls outside the permissable scope of discovery under 10 CFR 2.740(b) in that it does not relate to any matter in controversy in this proceeding nor is it reason-ably calculated to lead to the discovery of admissable evidence.

DATED: August 27, 1979 Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WILLIAMS B3 / W "Y " 1 ~

F. Theodore Thomsen Attorneys for Applicants 1900 Washington Building Seattle, Washington 98122 Phone (206) 682-8770 Of Counsel:

Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue N.W.

Washington, D. C. 20036

_,_ 1146 085

UNITED STATES OF AMERICA

! NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

i In the Matter of )

1

)

PUGET SOUND POWER & LIGHT COMPANY,) DOCKET NOS.

4 et al. )

l ) 50-522

(Skagit Nuclear Power Project, ) 50-523 Units 1 and 2) )

)

1 CERTIFICATE OF SERVICE

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I hereby certify that the following:

Applicants' Response to Intervenor SCANP's Interrogatories to Applicant dated August 21, 1979 1

in the above-captioned proceeding have been served upon the persons shown on the attached list by depositing copies thereof i

in the United States mail on August 28, 1979 with proper postage affixed for first class mail.

DATED: August 28, 1979 T _ fe!/ 1J 8 { m M n ~

F. Theodore Thomsen '*s Counsel for Puget Sound Power &

Light Company 1900 Washington Building Seattle, Washington 98101 11'46 086

Date: August 28, 1979

• Valentine B. Deale, Chairman Robert C. Schofield, Director Atomic Safety and Licensing Board Skagit County Planning Department 1001 Connecticut Avenue, N.W. 218 County Administration Building Washington, D. C. 20036 Mount Vernon, WA 98273

• Dr. Frank F. dooper, Member Richard M. Sandvik, Esq.

Chairman of Resource, Ecology, Assistant Attorney General Fisheries and Wildlife 500 Pacific Building

i. University of Michigan 520 S.W. Yamhill School of Natural Resources Portland, OR 97204 l Ann Arbor, MI 48109 Roger M. Leed, Esq.

• Gustave A. Linenberger, Member Room 610 Atomic Safety and Licensing. Board 1411 Fourth Avenue Building

[ U.S. Nuclear Regulatory Commission Seattle, WA 98101 Washington, D. C. 20555

• CFSP and FOB Alan S. Rosenthal, Chairman Eric Stachon I. Atomic Safety and Licensing 2345 S.E. Yamhill Appeal Board Portland, OR 97214 U.S. Nuclear Regulatory Commission Washington, D. C. 20555

• Robert Lowenstein, Esq.

Lowenstein, Newman, Reis, Dr. John H. Buck, Member Axelrad & Toll Atomic Safety and Licensing 1025 Connecticut Avenue, N.W.

Appeal Board Washington, D. C. 20036 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Warren Hastings, Esq.

Associate Corporate Counsel Michael C. Farrar, Member Portland General Electric Company Atomic Safety and Licensing 121 S.W. Salmon Street Appeal Board Portland, OR 97204 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 James W. Durham Portland General Electric Company Docketing and Service Section 121 S.W. Salmon Street jg Office of the Secretary. Portland, OR 97204 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Richard D. Bach, Esq.

(original and 20 copf.es) Rives, Bonyhadi, Drummond & Smith 1400 Public Service Building

• Richard L. Black, Esq. 920 S.W. 6th Avenue Counsel for NRC Staff Portland, OR 97204 U.S. Nuclear Regulatory Commission Office of the Executive Legal Canadian Consulate General Director Donald Martens, Consul Washington, D. C. 20555 412 Plaza 600 6th and Stewart Street Nicholas D. Lewis, Chairman Seattle, WA 98101 Energy Facility Site Evaluation Council

• Patrick R. McMullen, Esq.

820 East Fifth Avenue Skagit County Prosecuting Attorney Olympia, WA 98504 Courthouse Annex Mount Vernon, WA 98273 Thomas F. Carr, Esq.

Assistant Attorney General Temple of Justice

• Personally served at hearing Olympia, WA 98504 ,

on August 27, 1979.

8/22/79 1146 087