ML19320D545

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Objection to Second Set of NRC Interrogatories.Questions Are Not Based Upon New Info in Ser.Certificate of Svc Encl
ML19320D545
Person / Time
Site: Crane 
Issue date: 07/14/1980
From: Weiss E
SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
Shared Package
ML19320D542 List:
References
NUDOCS 8007210495
Download: ML19320D545 (2)


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4 DOCKETED N1 usNRC UNITED STATES OF AMERICA

[.

JUL 14 $80> d NUCLEAR REGULATORY COMMISSION OMceof the Secrthry 0;cketing & Mce p Bg{h BEFORE THE ATOMIC SAFETY AND LICENSING BOAR Cn 4

In the Matter of

)

)

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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UNION OF CONCERNED SCIENTISTS OBJECTION TO SECOND SET OF NRC STAFF INTERROGATORIES On July 7, 1980, UCS received a document entitled "Second Set of NRC Staff Interrogatories of Union of Concerned Scien-tists," dated July 1, 1980.

A copy is attached.

UCS objects to these interrogatories because they are clearly not " based upon new information in the SER."

Memoran-

~

dum and Order on Prehearing Conference of May 13, 1980, Sl. op.

at 6.

All of the questions could have been asked at virtually any time and none eithers references nor is related to the SER.

Respectfully submitteu,

~

'Ellyn R.

Weiss HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C.

20006 (202) 833-9070 DATED:

July 14, 1980 800'tg 3 o

e G

UNITED STATES OF AMERICA o'ocKETED h

usMRQ NUCLEAR REGULATORY COMMISSION E

JUL 141960> d BEFORE THE ATOMIC SAFETY AND LICENSING EOAEIY Omaof theSecNlER

  • Dodating & W
  • y' p

e

)

In the Matter of

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)

METROPOLITAN EDISON

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COMPANY, ~et al.,

)

Docket No. 50-269

.)

.(Restart)

(Three Mile Island

)

Nuclear Station, Unit

)

No. 1)

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3 CERTIFICATE OF SERVICE I.hereby certify that a copy of the " Union of Concerned Scientists Objection to Second Set.of NRC Staff. Interrogatories" was hand delivered this 14th day of July, 1980 to the following parties:

Secretary of the Commission

~

~ ATTN:

Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555

  • Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830
  • Dr. Linda W. Little 5000 Hermitage Drive Raleiegh, North Carolina 27612 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 "M" Street, N.W.'

Washington, D.C.

20006

, James Tourtellotte, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555

~

/

./

Ellyn R.. Weiss

  • mailed postage pre-paid

. _. _