ML19340D886
| ML19340D886 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 11/08/1978 |
| From: | Edgar G, Gallen K GENERAL ELECTRIC CO., MORGAN, LEWIS & BOCKIUS |
| To: | |
| Shared Package | |
| ML19340D878 | List: |
| References | |
| NUDOCS 8101050506 | |
| Download: ML19340D886 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-70 GENERAL ELECTRIC COMPANY
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Operating License (Vallecitos Nuclear Center -
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No. TR-1 General Electric Test Reactor)
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(Show Cause)
LICENSEE'S NINTH DISCOVERY STATUS REPORT The General Electric Company (GET, the licensee in the above-captioned proceeding, herewith submits its ninth status report on discovery and related matters.
1.
GE has responded to the Intervenors' dis-covery requests as follows:
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Discovery Served Received by Interval Between GE Response Number of Days CE GE Counsel Service Date and Response Preceded Date Discovery Rules of Practice Opened Deadline Cong. Dellums' Request 3/31/78 4/4/78 14 4/25/78 8
for Production of Docu-
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ments, dated March 30, 1978 F0E Interrogatories 4/19/78 4/24/78 33 5/5/78 3
(First Set), dated April 19, 1978 Cong. Dellums' Inter-5/9/78 5/12/78 53 5/22/78 4
rogatories (First Set),
dated May 9, 1978 F0E Interrogatories 5/9/78 5/12/78 53 5/24/78 2
(Second Set), dated May 9, 1978 1 - 4 above 6/7/78, GE Supplemental Answers to 1 - 4 above s-F0E Interrogatories 6/6/78 6/12/78 81 6/14/78 9
(Third Set), June 12, 1978 Cong. Dellums' Inter-6/23/78 6/26/78 98 6/30/78 10 rogatories (Second Set),
dated June 23, 1978
7 Cong. Dellums' Inter-7/17/78 7/20/78 122 7/31/78 3
rogatories (Third Set),
dated July 17, 1978 2, 3, and 4 above 7/31/78, CE Supplemental Answers to 2, 3, and 4 above
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F0E Interrogatories 7/24/78 7/26/78 129 Inter, 8/8/78 2
(Fourth Set), and Request for Production 4
of Documents dated July 24, 1978 Docu. 8/21/78 7
Cong. Dellum's Inter-7/25/78 7/28/78 130 8/9/78 2
rogatories (Fourth Set),
dated July 25, 1978 Cong. De11um's Inter-8/3/78 8/7/78 139 Inter. 8/10/78 11 rogatories (Fifth Set) and Request for Pro-duction of Documents 3
Docu.
8/10/78 26 dated August 3, 1978 s_/
F0E Request for Production 8/9/78 8/11/78 145 8/21/78 21 of Documents dated August 9, 1978 F0E Interrogatories (Fifth 9/25/78 9/28/78 192 10/6/78 6
Set) dated September 25, 1978 i
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On August 8, 1978 Congressman Dellums sub-mitted Intervenors' Motion To Compel Answers To Interroga-tories.
The motion sought an order compelling the Licensee to take and provide Intervenors with photographs of specified cooling pipes and supports.
The Licensee filed its Response To Intervenor's Motion To Co=pel Dated August 8, 1978 And Cross Motion For Protective Order on August 21, 1978.
The NRC Staff submitted its Response To Intervenors' Motion To Compel on August 29, 1978.
Both the Licensee and the Staff oppose the Congressman's motion.
On August 18, 1978 Congressman Dellums submitted Intervenors' Motion To Compel Answers To Interrogatories.
The interrogatories involved requested information concerning the containment design for GETR.
The Licensee responded to this motion on August 30, 1978; Licensee's Response To Inter-venors' Motion To Compel Dated August 18, 1978 And Cross Motion For A Protective Order.
The Licensee filed a supplement l
to its Response on August 31, 1978.
The NRC Staff is not j
required to file a response to this motion and has evidently i
chosen not to do so.
Each of the above described motions, along with full and complete responses to each motion are currently l
before the Board for its consideration.
The issues raised i
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On the dates listed below the following representa-tives, consultants, advisors, and/or experts affiliated with the Intervenors inspected the trenches being dug on or in the vicinity of the GETR site in connection with GE's expanded geological program to resolve certain issues related to the 1/
possible existence of a fault in this araa. -
October 17, 1978 Glen Barlow October 27, 197T Andrew Baldwin Robert Stolzman Barbara Shockley Lore Kohn Allison Lewis Ted Harrison Jack Turk Ralph Gray Len Peters Sue Hirschfeld Glen Barlow
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For a detailed description of this program, see the letter from D. Swanson of the NRC Staff to the Licensing Board, dated August 29, 1978, and the letter from R. W. Reid, Chief, NRC Operating Reactors Branch # 4 to GE, dated September 13, 1978.
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October 31, 1978 Andrew Baldwin Robert Stolzman Jack Turk Respectfully submitted, d.
eorge L. Edgar Attorney for General Electric Company Of Counsel Kevin P. Gallen Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Dated:
November 8, 1978 l
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