ML19290D530

Response to NRC First Set of Interrogatories.Intervenor Will Rely on NRC & Licensee Witnesses' cross-examination.Will Identify Names of Witnesses Prior to End of Discovery. Certificate of Svc Encl

ML19290D530
Person / Time
Site:	Three Mile Island
Issue date:	02/03/1980
From:	Pollard R CHESAPEAKE ENERGY ALLIANCE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8002220126
Download: ML19290D530 (2)

Text

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UNITED STATES OF AMERICA 47,%

- NUCLEAR REGULATORY COMMISSION RWORE THE ATOMIC SAFETI AND LICENSING BOARD

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Y s In the Matter of NETROPOLITAN EDISON COMPANY ej g. Docket # 50-289 p <g (Three Mile Island, Unit 1 ) ) I q, C

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CEA RESPONSE TO FIRST SET OF NRC STAFF INTERROGATORIES _

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Intervenor, Chesapeake Energy Alliance, hereby submits its response to the First Set of NRC Interrogatories to Intervenors:

1 &2 CEA has not identified yet the witnes ses that it intends to call. CEA notes that given the finances available to it to participate in these oo proceedings, it expects to rely principally on cross examination of witnesses of NRC and Licensee, unless the Board or Core 11ssion rules favorably on pending or future motions pertaining to funding of intervenors. CEA will identify the relevant NRC a Licensee witnesses through its interrogatories to NRC and Licensee, and will submit the appropriate information pertaining to those witnesses prior to the close of discovery.

3 & 14 Not applicable.

Respectfully sub '*ed

),

Robert O. Pollard, for Dated: February 3,1980 CHESAPEAKE ENERGY ALLIAF. -1, INC.

• 8002220 5

, UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1)

CERTIFICATE OF SERVICE I do hereby certify that I served a true and correct copy of the foregoing document on the below listed parties by first-class mailing:

Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 37830 Dr. Linda W. Little 5000 Hermitage Drive Raleigh, NC 27612 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, DC 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 Resp 11y submi d, r *  ! .

'Y Dated: h 3,l l$o Robert O. Pollard, for CHESA.PEAKE ENEF.G'I ALLIANCE