ML19350C636
| ML19350C636 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/19/1981 |
| From: | Rooney M GENERAL ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8104060502 | |
| Download: ML19350C636 (3) | |
Text
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Dated:
March 19, 1981 8
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UNITED STATES OF AMERICA 9 ~4 D g rg 4
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NUCLEAR REGULATORY )MMIS SION 3
24 ;gg7, 'I BEFORE THE ATOMIC SAFETY AND LICENSING BOAg v!!n afk u
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E In the Matter of
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Docket No. 70-1308 (Renewal of SNM-1265)
(GE Morris Operation Spent
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Fuel Storage Facility)
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MOTION OF GENERAL ELECTRIC COMPANY FOR LEAVE FOR ADDITIONAL DISCOVERY AGAINST INTERVENORS, ROREM, ET AL. AND THE STATE OF ILLINOIS Now comes General Electric Company, by its attorneys, and respectfully requests that this Board grant it leave to file additional discovery requests against both intervenors to this proceeding.
This motion is filed today in compliance with this Board's order of February 19, 1981.
General Electric seeks leave to file interrogatories and document production requests regarding only those proposed Additional Contentions that are ultimately admitted by this Board.
The interrogatories, which General Electric seeks to ask, and the document production request, which General Electric seeks to submit, are being filed today contemporaneously with this motion.
In support of its motion, Gener al Electric states that the essence of its request is foz the basis for each
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Additional Contention admitted by the Board.
Accordingly, General Electric seeks the documents supporting each such contention, the regalatory and factual basis for each, and the substance of any e: pert testimony or opinion evidence regarding each.
Therefore, General Electric requests leave to obtain the additional discovery it specifically seeks in the four discovery requests filed today, but only with regard to those Additional Contentions that are ultimately admitted by the Board.
Respectfully submitted, GENERAL ELECTRIC COMPANY (A
til/ b WIN i
Ronald W.
Szwajkowski /
Matthew A. Rooney Its Attorneys OF COUNSEL:
MAYER, BROWN & PLATT 231 South LaSalle Street Chicago, Illinois 60604 (312) 782-0600 N
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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GENERAL ELECTRIC COMPANY
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Docket No. 70-1308 Consideration of Renewal of
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Materials License No. SNW-1265)
Issued to GE Morris Operation )
Fuel Storage Installation
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CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a copy of MOTION OF GENERAL ELECTRIC COMPANY FOR LEAVE FOR ADDITIONAL DISCOVERY AGAINST INTERVENORS ROREM, ET AL. AND THE STATE OF ILLINOIS, in the above-captioned proceeding on the following persons by causing the said copies to be deposited in the United States mail at 231 South LaSalle Street, Chicago, Illinois, in plainly addressed and sealed envelopes with proper first class postage attached before 5:00 P.M.
on March 19, 1981:
Andrew C. Goodhope, E s q.,' Chairman Susan N.
Sekuler, Esq.
Atomic Safety and Licensing Board George William Wolff, Esq.
3320 Estelle Terrace Office of the Attorney General Wheaton, Maryland 20906 188 West Randolph Street Suite 2315 Dr. Linda W.
Little Chicago, Illinois 60601 Atomic Safety and Licensing Board 5000 Hermitage Drive Marjorie Ulman Rotht-hdi1, Esq.
Raleigh, North Carolina 27612 United States Nuclear Regulatory Commissio?
Dr. Forrest J.
Remick Washington, D.C.
20555 Atomic Safe'ty and Licensing Board l
305 East Hamilton Avenue Atomic Safety and Licensing State College, Pennsylvania 16801 Board Panel U.S. Nuclear Regulatory Atomic Safety and Licensing Appeal Commission Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commissio~n Washington, D.C.
20555 Docketing and Service Section Office of the Secretary Bridget L. Rorem U.S.
Nuclear Regulatory Essex, Illinois 60935 Commission Washington, D.C.
20555 Everett J. Quigley R.R.
1, Box 378 Kankakee, Illinois 60901 y
Matthew A.
Rooney j/
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