ML19309C632
| ML19309C632 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/03/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8004090096 | |
| Download: ML19309C632 (6) | |
Text
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March 3, 1980 LN
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION pfa 5 GSO P -5 Cilitt CI ** se e
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289-
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S MOTION TO EXTEND SCHEDULE FOR i
RESPONSES TO INTERVENOR INTERROGATORIES Licensee reluctantly requests that the schedule for i
Licensee's responses to interrogatories filed by intervenors on or after February 13, 1980, be extended from March 17,'1980 to March 31,'1980.
As required.by the Board's Memorandum on Revised Discovery Schedules dated February 20, 1980, Licensee will, however, file any objections it may have to such inter-rogatories within 15 days following the service thereof upon Licensee.
Since the time of the Board's rulings extending the.
time for discovery requests, i.e.
first extending the deadline for discovery requests to February 16, 1980, and then further extending the deadline for discovery requests to February 25,
- 1980, Licensee has received the following interrogatories:-
February 14 --Lewis Third Set February 15 - Newberry First' Set 4
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February 16 - Aamodt First Set February 21 --Lewis Fourth Set February 22 - Aamodt Second Set-February 22 - Aamodt Third Set-February 22 - Aamodt Fourth Set February 22 TMIA Seventh Set February 25 - ANGRY Second Set February 25 - Sholly Fourth Set February 25 - Aamodt Fourth (sic) Set i
February 25 - Aamodt Third (sic) Set February 25 - UCS Second Set February 25 - CEA First Set Collectively the above interrogatory requests contain approximately 315 interrogatories, not counting subdivisions.
The interrogatories filed by the Aamodts, CEA and Newberry rep--
I resent the first discovery efforts made by these intervenors since the formal discovery period opened on December 18, 1979, at which time it was contemplated that all general discovery l
l would be completed by February 16, 1980.
Licensee doubts whether under any circumstances it would be.possible to respond by March 17 to the large volume of last-minute interrogatories filed by intervenors.
Responses must be coordinated by Licensee's counsel in Washington with GPU licensing engineers-in Pa,rsippany, New Jersey,-and input to.most of the interrogatories must be obtained from Met Ed.
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personnel at the TMI' site, from Met Ed's architect-engineer in Reading, Pennsylvania, ' or from B&W in Lynchburg, Virginia.
Certainly, however,- the March 17 date could not be met with-out severe interference, as predicted'by Licensee's counsel 1
at the February 13 prehearing conference, with the prepara-tion and filing of information requested by the NRC Staff for inclusion in its Safety Evaluation Report.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE h*/
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T ' G9 rge F.
frowbridge /
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f Dated: March 3, 1980 i
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J March 3, 1980 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
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(Restart)
(Three Mile Island Nuc. ear
)
Station, Unit No. 1)
)
i CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Motion to Extend Schedule for Responses to Intervenor Interrogatories,"
dated March 3, 1980, were served upon those persons on the attached Service List by_ deposit in the United States mail, postage prepaid, this 3rd day of March, 1980.
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I G/orge F. Trowbridge l
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- 1 Dated: March 3, 1980 i
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e UNITED STATES OF AMERICA NUCLEAR FIGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
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SERVICE LIST Ivan W. Smith,~ Esquire John A.
Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm*
j Board Panel Post Office Box 3265 U.S.
Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555
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Karin W.
Carter, Esquire Dr. Walter H.
Jordan-Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357
[
E81 West Outer Drive Harrisburg, Pennsylvania 17120 i
Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W.
Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101' James R.
Tourtellotte, Esquire (4)
Walter W.
Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U.
S. : Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C.-
20555 14th Floor, Strawberry Square Docketing and Service Section (21)
Office of the Secretary U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555 f
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... Jordan D.
Cunningham, Esquire Karin P.
Sheldon, Esquire Attorney for Newberry Township Attorney for People Against T.M.I.
Steering Ccamittee Nuclear Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W.,
Suite 506 Washington, D.C.
20006 Theodore A.
Adler, Esquire Widoff Reager Selkowitz & Adler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Sheldon, Harmon & Weiss Nuclear Power 1725 Eye Street, N.W.,
suite 506 433 Orlando Avenue Washington, D.C.
20006 State College, Pennsylvania 16801 Marvin I. Lewis Steven C.
Sholly 6504 Bradford Terrace 304 South Market Street Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bridford Marjorie M.
Aamodt R.
D.
5 Holly S.
Keck Coatesville, Pennsylvania 19320 Legislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 l
.