ML19309D619
| ML19309D619 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/11/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8004110029 | |
| Download: ML19309D619 (5) | |
Text
March 11, IWWD
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UNITED STATES OF AMERICA
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BEFORE THE ATOMIC SAFETY AND LICENSING BOA
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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
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f Station, Unit No. 1)
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LICENSEE'S OBJECTIONS TO UCS SECOND SET OF INTERRCGATORIES 179 request-Licensee objects to UCS Interrogatory No.
ing Licensee's present position on each of the UCS contentions.
is irrelevant to the ultimate disposition of the UCS' request issues and, at the very least, is premature, as the Licensee has not completed its evaluation of these contentions or the Requiring Licensee to respond to this re-underlying facts.
quest would force it to adopt a position without adequate information and to disclose at a preliminary stage a tentative evaluation of UCS' contentions.
In addition, UCS Interrogatory 179 constitutes an attempt by UCS to ascertain the manner No.
An answer by in which Licensee is preparing for the hearing.
Licensee would necessitate divulgence of the mental impressions, conclusions and opinions of Licensee's counsel and other repre-as such, is protected from disclosure.
septatives and, 800AI106CWi
Licensee's objection is reinforced in-this proceeding by the. fact that Interrogatory No. 179 has been posed before the discovery process has been allowed to fulfill one of the central purposes of discovery contemplated by the Licensing Board, namely the clarification of intervenor contentions and the addition of basis and specificity thereto.
On Janu-ary 18, 1980, Licensee served UCS with a set of interrogatories designed to accomplish just this purpose.
No response to any 1
of these interrogatories has been received to date.
It is unreasonable for UCS to ask Licensee for its position, much less its present position, on UCS contentions which remain so undefined.
Licensee reminds UCS that its final position on each of UCS' contentions will be developed in prepared testimony and served on UCS in advance of the hearing session at which the contentions will be considered.
UCS does not face the situation, for which discovery is in part designed, of surprise testimony at the hearing.
Licensee further objects to Interrogatory Nos. 182 through 184 on the-ground that they are outside the scope of UCS' con-tentions.
Respectfully submitted, SHAW, PI"TMAN, POTTS & TROWBRIDGE Y
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G[orgeF._ Trowbridg[
Dated: March 11, 1980 L -
March'll, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY 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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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Objec-tions to UCS Second Set of Interrogatories," dated March 11, 1980, were served upon_those persons on the attached Service
' List by. deposit in the United States mail, postage prepaid, this lith day of. March, 1980.
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A Ge[rge F.
Trowbridge
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Dated: March 11, 1980 e
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UNITED STATES OF AMERICA NUCLEAR REGULATORY 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)
)
l SERVICE LIST Ivan W.
Smith, Esquire John A.
Levin, Esquire Chairman Assistant Counsel i
Atcmic Safety and Licensing Pennsylvania Public Utility Ccan Board Panel Post Office Box 3265 U.S.
Nuclear Regulatory Commission
.Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 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 Oak Ridge, Tennessee 37830 John'E. Minnich.
Dr. Linda W.
Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners
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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 4
Office of the Executive Legal Director Consumer Advccate U.
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Nuclear Regulatory Commission Office of Consumer Advocate
- Washington, D.C.
20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania. 17127 Docketing and Service Section (21)
Office of the Secretary U.
S. Nuclear Regulatory. Commission ajhington, D.C.
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Karin P. Sheldon, Esquire Jcrdan D. Cunningham, Esquire Attorney for People Against Attorney for Newberry Township Nuclear Energy T.M.I. Steering Committee Sheldon, Harmon & Weiss n.w., Suite 506 2320 Scr:h Second Stree:
1725 Eye Street, Harrisburg, Pennsylvania 17110 Washing:cn, D.C.
20006 ncler, -scuire Aneocore A.
Robert Q. Pollard Widoff Reager Selkowitz & Adler 609 Montpelier Street Post Office Sox 1547 Baltimore, Maryland 21218 Harrisburg, Pennsylvania 17105 Chauncey Kepford i
Ellvn R. Weiss, Esquire Judith H. Johnsrud A:tornev for the Union of Concerned Envircnmental Coalition on
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-- e. l.e.s Nuclear Power e4 Shelden, Harmon & Weiss 433 Orlando Avenue c 4.e 506 State College, Pennsylvania 16501
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3 Marvin I. Lewis Steven C.
Shollv 6504 Erac: orc Terrace 19149
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Philadelphia, Pennsylvania m.
Mechanicsburg, Pennsylvania 17055 Aamodt
{arjorie M.
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Gail 3radford 19 20 Holly S. Keck Coatesv111e, Pennsylvania 2
.ecisAa._:cn Chairman sAnti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 sua[s[W 3f) hum 1[
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