ML19289C502
| ML19289C502 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 12/13/1978 |
| From: | Blum S BLUM & SHEELY |
| To: | |
| References | |
| NUDOCS 7901170031 | |
| Download: ML19289C502 (3) | |
Text
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UNITED STATES OF AMERICA d
NUCLEAR REGULATORY COMMISSION y
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in the Matter of
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T ROO3r DUKE POWER COMPANY
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(Amendment to Materials License
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SNM-1773 for Oconee Nuclear Sta-
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Docket No. 70-2623 tion Spent Fuel Transportation
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and Storage at McGuire Nuclear
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Station)
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MOTION TO COMPEL Pursuant to Rule 2.740(f), Intervenor moves the Board to compel discov-ery in this matter, and as grounds therefore, says:
1.
In a timely fashion, Intervenor has requested an assortment of docu-ments related to this IIcensing matter.
On December 8, 1978, Applicant re-sponded that copies of the documents requested "are available for review in William L. Porter's office.
" (see attachments). -
2.
The documents are:
(a) a June 2,1978 study, referred to in previous answers to discov-e ry; (b) notes, calculations and clarifications relating to (a);
(c) correspondence f rom Applicant to Staff (we already have Staff to Applicant); and of that, in particular, responses to requests for add-itional information requested by R. W. Starosteckt dated 5/19/78 and 7/12/78.
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3.
We believe these things are such that we should have gotten them in a routine manner.
They are clearly relevant to the issue.
4.
A request to produce documents of this sort does not mean that they shall be produced in a place and at times when they are useless.
We need copies so that experts can review the materials, and so that Mr. Riley can 790117003/
. P work on it, which of necessity means during his spare time.
Granting us the right of a view in Mr. Porter's office is not full and complete discovery of technical and scientific materials.
5 On several occasions, the first being months ago, intervenor has asked for Scandia Laboratories' impact tests on the NAC-1 cask.
On October 26, 1978 (see Response to Interrogatorie, No. 5), Applicant promised this document by October 16, 1978.
To date, this document has not been forthcoming.
WHEREFORE, Intervenor moves for an order compelling discovery of these documents and for copies of same to be provided to us at both addresses of Intervenor.
Dated:
Decemberf,3_,1978.
BLUM AND SHEELY
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by SHECLEY BLUM j
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418' Law Buildifg 730 East Trade Street Charlotte, North Carolina 28202 (704) 376-6591
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REQq CERTIFICATE OF SERVICE ONDEWCa
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I hereby certify that copies of the attached in the captioned matter have been served on the following by depositing [same in the United States mail
/A day of
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, 197 Robert M. Lazo, Esq., Chairman Brenda Best Atomic Safety and Licensing Board Carolina Action 11 S. Nuclear Regulatory Commission 1740 East independence Boulevard Washington, D.C.
20555 Charlotte, North Carolina 28205 Dr. Emme S A. Luebke Jeremy Bloch Atomic 4 /ety and Licensing Board Safe Energy Alliance U. S. Nuclear Regulatory Commission 1707 Lombardy Circle Washington, D.C.
20555 Charlotte, North Carolina 28203 Dr. Cadet H. Hand, J r., Di rector Richard P. Wilson Bodena Marine Laboratory of California Assistant Attorney General Post Office Box 247 State of South Carolina Bodega Bay, California 94923 2600 Bull Street Columbia, South Carolina 29201 5
Mr.
Jesse L. Riley, President Carolina Environmental Study Group Chairman, Atomic Safety and Licen-854 Henley Place sing Appeal Board Charlotte, Nor'.h Carolina 28207 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Fdward G. Ketchen, Esq.
Mr. Chase R. Stephens Counsel for NRC Regulatory Staff Docketing and Service Section Office of the Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Vashington D.C.
20555 William L. Dorter, Esq.
Chairman, Atomic Safety and Licen-Associate General Counsel sino Board Panel Duke Power Company U.S. Nuclear Regulatory Commission Post Office Box 2178 Washington, D.C.
20555 Charlotte, North Carolina 28242 J. Michael McGarry, ll!
Anthony Z. Roisman, Esq.
Debevoise and Liberman Matural Resources Defense Council Suite 700 Mk $
806 15th Street, Northwest 917 15th Street, H.W.
g Washington, D.C.
20005 shington, D.C.
20005 1
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-Charles T. Gaddy q'
4 Davidson Chapter of PIRG) h fy l
N A Q
Davidson College Union
/kA Davidson IlC 28036
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