ML20030C467
| ML20030C467 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/16/1981 |
| From: | Halligan T CITIZENS AGAINST NUCLEAR DANGERS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8108260135 | |
| Download: ML20030C467 (2) | |
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AUG 2 41981 > :-
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'S UNITED S3TES OF AMERICA y
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g g g a sen6ce NUCLEAR REGULA'IJHY CO!G!ISSION O
- BEFORE THE ATOMIC SAFETY AND~ LICENSING BOA
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a In Matter Of:
PENNSYLVANIA POWER & LIGHT CO.
Berwick Atomic Po M K an @
and Susquebanna Units 1'&-2
- ALLEGHENY ELECTRIC COOPERATIVE, INC.
Docket Nos. 50-387 & 50-388 CITIZENS AGAINST NUCLEAR DANGERS-MOTION FOR PROTECTIVE ORDER The Citizens AEainst Nuclear Dangers- (Citizens) oppose the last minute imposition of. discovery on a portion of Contention 2by the Applicants.
Their interro6atories aro. primarily intended to cause some diversion froto PP&L's atomic power plant inadequacies in protecting the water quality of the Susquehanna River.
But, the Applicants have not demonstrated a valid need for the data.
It may be viewed in th'e press that if this type of maneuver is condoned, it smacks of collusive overtones.
The cxcessive number of. interrogatories are definitely unreasonable and unwarrented by any rule of fairness.
The Citizens cannot afford the time and money to comply, which is justifiable
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cause, under NRC' rules, for the fo11 win 6 motion.
The Citizens move the ASLB to issue a protective order-nullifyin6 the Applicants unjust and unfair interrogatories.
It must be pointed out that the Citizens responded extensively to the Applicant's questions on this subject at Wilkes-Barre, Pa. on August 11, 1981, and extended those remarks (althought ga65ed from y
elaboration) the followin6 day before the ASLB in an attempt to l
clarify what is known about the sta tus of Contention 2.
The fact '-
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that there was not a sincere interest by the Applicants in the
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Nl}U 8108260135 810816 I
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2 Citizenc's replies is indicative of ulterior sotives.
Incidentally, no other party sou6ht eleventh-hour discovery.
The Applicants are by their action obstructin6 the hearin6 process with their needless questionin6 A few weeks from now, the Applicants will have the relevant information on the contentions, when direct testimony is submitted.
That should be more than suf ficient.
l Respectfully submitted l
M Dated: Au6ust 16, 1981 correspondent /
sf CERTIFICATE OF SERVICE I hereby certify that copies of Citizens Against Nuclear Dangers Motion For Protective Order have been served on all parties to this proceedin6 by deposit in the U.S. mail, first class, this 16th day of August, 1981.
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