ML19257D069
| ML19257D069 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 01/18/1980 |
| From: | Black R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML19257D070 | List: |
| References | |
| NUDOCS 8001310320 | |
| Download: ML19257D069 (2) | |
Text
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UNITED STATES OF c.'.:_# I C A NUCLEAR REGULATORY CO:":ISSION r-n-r --
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- n f p3 In the Matter of
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PUGET SOUND PO'n'ER & LIGHT CO"PANY, )
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Docket Nos. STN 50-522
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STN 50-523 (Skagit Nuclear Power Project,
)
Units 1 and _'
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NRC STAFF'S OBJECTION TO SCANP'S INTERROGATORIES TO STAFF REGARDING SAN JUAN ISLANDS SEISMIC PROFILES On October 30, 1979, Intervenors SCANP filed interrogatories to the NRC Staf f which relate to seismic profiles run by Western Geophysical Company in 1971 in the San Juan Islands.
These profiles were acquired by the Applicant in August-September 1979 after a request by the NRC on August 23, 1979 to obtain them, if possible.
SCANP's stated purpose in submitting these interrogatories is to seek information regarding the existence and ccntent of the profiles "in order to determine whether Applicant has made a material false statement, as that term is used in Section 186 of the Atomic Energy Act, 42 U.S.C. a 2236."
SCANP Interrogatories, p. 1.
The NRC Staff objects to SCANP's interrogatories because the information sought is not relevant to the subject matter involved in the proceeding nor does it appear to be reasonably calculated to lead to the discovery of admissible evi-dence as required by 10 CFR 9 2.740(b)(1).
The question of whether the Applicant has made a material false statement with regard to the seismic profiles is not a subject matter involved in this proceeding.
However, to inform the Board and SCANP as to the sequence of events that led to the Applicant's submittal of the 1842 348 8001310 3 2 0 subject seismic profiles, we are attaching the !.ffidavit of liarold E. Lefevre.
- .i. Lefe tu'.
mfficm.a 1;.m cm.
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.. u.r.. o r e of the t. 1. L t. 6 t
of the profiles in the murr.cr of 1979 through the Simgit revict effortc of the U.S. Geological Survey.
Respectfully. submitted,
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- (f/!:,,(;/ >AJL Richard L. tlack Counsel for NRC Staff Dated at Bethesda, Fbryland this 18th aay of January, 1980 ji i,f fl.0] hi lj
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1842 349 -