ML19305B923

Responds to ASLB 800213 Request for Recommendations Re Proposed Schedule for Followup Discovery Requests.All Discovery,Including to Be Completed by 800516.W/Certificate of Svc

ML19305B923
Person / Time
Site:	Three Mile Island
Issue date:	02/14/1980
From:	Sholly S AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8003240003
Download: ML19305B923 (3)

Text

.

o

' ~ REI.M ConnEspO.WE.M UNITED STATES OF AMERICA NUCLEAR REGULATORY CO>NISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BCAPS i 1

m In the Matter of- G ~

l s i METROPOLITAN EDISON COMPANY Dock No -289 '

.(Three Mile Island, Unit 1) os@C -

) 6-2 960 # I O ~3 INTERVENOR STEVEN C. SHOLLY S d RECOMMENDATIONS ~FOR FOLLOW- j UP DISCOVERY REOUEST SCHEDULE S l j

At the Second Special Prehearing Conference on 13 Mi>rvis ,

February 1980, the Board directed parties to present recommendations to the Board for a proposed schedule for follow-up discovery requests. Intervenor Steven C. Sholly offers the following for Board consideration 17 March-----Last date by which to file responses to interrogatories (established by the Board on 13 February 1980) 26 March-----Last date on which depositions may be taken (established by the Board on 13 February 1980) . .

27 10 March April to--Parties analyze

. discovery resp (onses requests to initial round) and identify additional persons to be deposed and prepare -

follow-up interrogatories and document requests ,

.10 April to--Followup. discovery requests 17 April to be filed during this week,

• including interrogatories, notices of deposition, and document requests, and requests for site inspection (2.741) 18 April to--Responses to follow-up discovery

. 5 May requests are filed (depositions to be completed by 1.6 May--30 days) .

g0

, 8008240 4

- . - . i

.a. . , ,

t Under this proposed schedule, all discovery, including depositions, site inspection and document requests (10 CFR

~2.741), and interrogatories would be completed by 16 May

~

1980. Intervenor then envisions a Prehearing Conference on or dbout 21 May and continuing untti the necessary business was completed. Filing of testimony on those issues identified

' ~

for early" litigation (on which parties agree can be litigated

~ '

wi.thout completion of SER discovery period) would be due

' ;15~ days later (probably by 7 June, assuming the Prehearing Conference lasts until 23 May). Litigation could proceed ,,

beginning 12 June 1980 on the first issue of the proceeding.

Discovery on the SER would commence upon its service to the parties. Assuming such service is complete by 18 April, discovery requests of all forms would be due by 2 May, and' responses would be due by 16 May. Depos,itions may take longer, depending upon how many would be identified, but under no circumstance would they extend beyond 2 June.

' Respectfully submitted,  ;

v h.h , ? . h k b .. l i

Steven 304 South C.Market Sholly N'eet r l Mechanicsburg, PA 17055 DATED: 14 February 1980 h--717-766-1857 '

w--717-566-3237

, 566-3238 j

- j 1

/

5

- 5

/ occY.ETED 4

. /g usEC }

CERTIFICATE OF SERVICE [2 FEB 221950 > 70 I:hereby certify that the attached document '.h wa omcecl$8 s.lsrepdhN Y'. N all' wrties of record--as cf the date of filing, by*51 it'"i . y the Jnited States Mail, postage prepaid, 'or by hand '

/M " , ' g on this .of W/*t.W'/ 1980.

Steven C. Sholly ,e

'Ivan W. Smith, Esquire Theodore A. Adler, Esq.

. Chairman, Atomic Safety and Licensing. Board Panel- a $i ur A 17105 U.S. Nuclear Regulatory John E. Minnich H

Commission Dauphin County Courthouse Washington, D.C.

20555 Front and Market Sts.

Dr. Walter H. Jordan Harrisburg, PA 17101 881 West Outer Drive- Jordan D. Cunningham, Esq.

Oak Ridge, TN 37830 2320 N. 2nd St.

Dr. Linda W. Little Harrisburg, PA 17110

. 5000 Hermitage Drive George F. Trowbridge, Esq."

'Raleigh, NC 27612- Shaw, Pittman, - Potts & Trowbridge James Tourte11otte, Esq. 1800 M Street, NW I Office of the-Executive ' Washington, D.C. 20036 Legal Director Ellyn Weiss, Esq.  !

U.S. Nuclear Regulatory Karen Sheldon, Esq.

Commission Sheldon, Harmon, & Weiss Washington, D.C.

20535 1725 Eye Street, NW l Docketing and Service Section Washingte , D.C.

Office.of the Secretary Holly S. Keck U.S.-Nuclear Regulatory 245 West Philadelphia St.

.Commisston York, PA 17404 Washington, D.C..

20555 John A. Levin, Esquire Robert Q. Pollard 609 Montpelier.St.

, Public Utility Commission Baltimore, MD '21218 P,O. Box 13265 Harrisburg, PA 17120 Chauncey Kepford Walter W. Cohen, Esquire 433 Orlando Avenue .

State College, PA 16801 Consumer Advocate 14th Floor, Strawberry Sq. Marjorie Aamodt Harrisburg, PA 17127 R e ville, PA 19320

. Karin W. Carter, -Esquire

. Asst. Attorney General 505 Executive House -

P.O. Box 2357 Harrisburg,-PA 17120

~ Marvin I. Lewis 6504 Bradford Terrace *

Philadelphia, PA' 19149 O

- . .