ML19330B215
| ML19330B215 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/07/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8007310138 | |
| Download: ML19330B215 (7) | |
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SHOLLY, 7/7/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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WTEQ CORRESPOEM Ir the Matter of
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Docket No. 50-289 W
METROPOLITAN EDISON COMPANY, et al.
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(RESTART)
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'Y INTERVENOR STEVEN C. SHOLLY n
OBJECTIONS TO SECOND SET g
Etze (sic, THIRD SET) of NRC STAFF INTERROGATORIES N lm The NRC Staff has served upon the intervenors a second general set of interrogatories.
This is the third such set served upon this intervenor, the first two sets having been served 12/27/79 and 02/01/80, respectively.
This third set contains general interrogatories on this intervenor's contentions to which this intervenor objects on grounds of untimeliness. The interrogatories which are objected to in the 7/1/80 filing are #1, #2, and #3.
These interrogatories are of a general nature and should have properly been served before the close of general discovery.
The discovery matters at issue at this point relate solely to the SER which issued 6/16/80. None of
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the interrogatories cbjected to bear any relation to the SER or information contained therein.
This intervenor will shortly file supplements to responses to previous interrogatories, and to the extent information requested in the most recent interrogatories is covered by prior interrogatories, answers will be forthcoming.
1 The interrogatories in the third set which are objected to request the following information:
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1.
Identification by author, title, dcte of publication, and publisher, h
of all books, documents, and papers which will be relied upon or
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OBJECTIONS TO STAFF INTERROGATORIES SHOLLY, 7/7/80 employed in presenting the direct case on this intervet or's contentions.
2.
Identify sLailarly those references intended to be utilized in cross-examination of prospective NRC witnesses.
3.
If representations made in any of this intervenor's contentions are based in whole or in part on any documents prepared by NRC Staff or the licensee which are contended to be deficient, specify the documents and particular portions and explain why they are deficient.
It is obvious that these interrogatories relate to general dircovery.
They are in no manner made specific to the SER. Each of the proposed interrogatories which are objected to could have been posed by the Staff during general discovery, with the understanding that, as required by regulations, responses would be
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supplemented upon rr.ceipt of new information.
This was not done in the case of these three interrogatories. They are impermissibly late, and there is no justification within the 7/1/80 filing for basing a " good cause" finding for lateness. Therefore, objection is made to Interrogatories #1, #2, and #3 in the NRC Staff filing of 7/1/80.
DATE:
7 July 1980 RESPECTFULLY SUBMITTED,
& c J.K Steven C.
Shelly
(}7 304 South Market Street Mechanicsburg, PA 17055 h--717/766-1857 w--717/233-4241 e
gG CC3?NDM 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
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S'tation, Unit No. 1)
CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor Steven Cs Shelly Objections to Second Set (sic, Third Setl of NRC Staff Interrogatories dated July 7,1980, which was hand delivered on July 7,1980, were.
served upon thosa persons on the. attached Service List by-deposit in the United States me.il, postage paid, this 9th. day of July, 1980.
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UNITED STATES OF AMERICA ngir yrgg NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC M LICENSING BOARD d'
Th DOCM In the Matter of usMRC
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METROPOLITAN EDISON COMPANY
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- r Docket No. 50-289 Oti::e ol de 34 y
(Restart)
(Three Mile Island Nuclear Dochayeg I. Samco Station, Unit No. 1)
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SERVICE LIST Ivan W. Smith, Esquire Karin W. Carter, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 Commission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James A. Tourtellotte, Esquire Offf e of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice Washington, D.C.
20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township Washington, D.C.
20555 T.M.l. Steering Committee 2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Commission Widoff Reaper Selkowit-6 Adier P.O. Box 3265 P.O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105
- Pctson on whose beh'alf service is being made.
Only Certificate of Service is enclosed.
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Chauncey Repford Ellyn Weiss, Esquire Judith H. Johnsrud Sheldon, Harmon & Weiss Environmental Coalition on Nuclear Power Suite 506 433 Orlando Avenue 1725 Eye Street, N.W.
State College, Pennsylvania 16801 Washington, D.C.
20006 Marvin I. Lewis
- Steven C. Sh,olly 6504 Bradford Terrace 304 South Market Street Philadelphia, Pennsylvania 19149 Mechanicsb'urg; Pennsylvania 17055 Marjorie M. Aamodt Holly S. Keck R. D. ~ 5 Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York George F. Trowbridge, Esquire 245 West Philadelphia Street Shaw, Pittman, Potts & Trowbridge York, Pennsylvania 17404 1800 M Street, N.W.
Washington, D.C.
20036 Karen Sheldon, Esquire Sheldon, Harmon & Weiss Susan Barley Suite 506 129 Cocoa Avenue 1725 Eye Street, N.W.
Hershey, Pennsylvania 17033 Washington, D.C.
20006 Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218 Only Certificate of Service
- Person on whose behalf service is bei:
so.
is enclosed.
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