ML20053D069

Response to First Set of Interrogatories & Document Production Requests & Motion for Protective Order Re Contentions 6,7,18,40 & 43.Certificate of Svc Encl

ML20053D069
Person / Time
Site:	Catawba
Issue date:	05/26/1982
From:	Guild R GUILD, R., PALMETTO ALLIANCE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8206040028
Download: ML20053D069 (4)

Text

UNITED STATES OF AMERICA .g^ r ,

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC $AFETY AND LICENSING BOARD' In the Matter of Docket Nos. 50-413 DUKE POWER COMPANY, ET AL. 50-414 f

(Catawba Nuclear Station, ) May 26, 1982

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Units 1 and 2)

PALMETTO ALLIANCE RESPONSES TO NRC STAFF'S FIRST SET OF INTERR0GATORIES AND DOCUMENT PRODUCTION REQUESTS

-and-MOTION FOR PROTECTIVE ORDER Intervenor Palmetto Alliance hereby responds to the NRC Staff's First Set of Interrogatories and Document Production Requests with the following

answers, objections, responses, and with a Motion for Protective Order.

i Applic. ants Duke Power Company, et al., served upon Palmetto Alliance their First Set of Interrogatories and Requests to Produce dated April 9,1982.

Palmetto Alliance responded fully to Applicants' discovery by Responses and Motion for Protective Order dated April 28, 1982, which are incorporated herein by reference. Copies were served upon the NRC Staff.

Palmetto Alliance served its First Set of Interrogatories and Requests to Produce together with its Motion to Require Staff Answers all dated April 20, 1982. Applicants interposed a general objection and moved for a i Protective Order. They gave no substantive answers to intervenor's interrog-atories nor did they agree to any requests to produce. Staff refused Palmetto Alliance's request to voluntarily answer interrogatories, produce documents, 1end documents and transcripts to intervenor, or give us extra copies of documents not needed by Staff, or to set up an accessible public document a room where .intervenor could review relevant materials. Staff has opposed 8206040028 820526 D*3 PDR ADOCK 05000413 0 PDR ll

Palmetto Alliance's Motion to require Staff answers to interrogatories and has provided us no substantive information whatsoever.

NRC Staff now serves its first Set of discovery on Palmetto relating to our Contentions 6, 7,18, 40, and 43, which were already the subjects of Applicantdiscovery and our responses. Each Interrogatory of the NRC Staff is either identical to one or more already propounded by Applicants, or is substantially the same as those already propounded, and in either event all discoverable information sought now by Staff has already been supplied in response to discovery by Applicants. No further information is available to intervenor since neither Duke et al., nor the Staff have answered a single discovery request. While this round of discovery was established by the Board to permit Palmetto Alliance to elicit sufficient information to enable it to make further specification of its above- enumerated contentions; to date it has been only the intervenors who have answered what has been asked.

Palmetto Alliance objects to providing further answer to Staff Inter-rogatories beyond those answers already given as unduly burdensome, time consuming, costly and oppressive, and calling for production of privileged communication between it and its attorney, including his private work product.

Intervenor will make available for inspection and copying those materials which it has agreed to produce for Applicants under the same terms.

Palmetto Alliance reiterates its Motion for Protective Order dated April 28, 1982, as related to NRC Staff discovery as well as that by Applicants, upon the basis as asserted therein as supplemented by this filing. In. addition we request that any further discovery against Palmetto Alliance , compulsion of discovery against Staff and Applicants, or further discovery by Palmetto, await resolution of the matters now pending before the Board.

A Y '

1 Robert Guild X 314 Pall MalU Columbia, South Carolina 29201 Attorney for Palmetto Alliance l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

DUKE POWER COMPANY, M al. Docket No. 50-413 50-414 (CatawbaNuclearStation, Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of PALMETTO ALLIANCE RESPONSES TO NRC STAFF'S FIRST SET OF INTERR0GATORIES'AND DOCUMENT PRODUCTION REQUESTS AND MOTION FOR PROTECTIVE ORDER in the above captioned matters, have been served upon the following by deposit in the United States mail this 26 th day of May ., 1982, i -

James L. Kelley, Chaiman George E. Johnson, Esq.

Atomic Safety and Licensing Office of the Executive Legal ~

Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Comission Comission Washington, D.C. 20555 Washington, D.C. 20555 i

Dr. A. Dixon Callihan William L. Porter, Esq.

l Union Carbide Corporation Albert V, Carr, Jr. , Esq.

P.O. Box Y Ellen T. Ruff, Esq..

Oak Ridge, Tennessee 37830 Duke Power Company P.O. Box 33189 Dr. Richard R. Foster Charlotte, North Carolina 28242 l P.O. Box 4263

Sunriver, Oregon 97701 Richard P. Wilson, Esq.

Assistant Attorney General Chairman State of South Carolina Atomic Safety and Licensing P.O. Box 11549 Board Panel Columbia, South Carolina 29211 i U.S. Nuclear Regulatory Comission Washington, D.C. 20555 i

l Chainnan Jesse L. Riley Atomic Safety and Licensing 854 Henley Place Appeal Board Charlotte, North Carolina 28207 U.S. Nuclear Regulatory Comission Scott Stucky Washington, D.C. 20555 Docketing and Service Station Henry A. Presler U.S. Nuclear Regulatory Comission Charlotte-Macklenburg Washington, D.C. 20555 Environmental Coalition 943 Henley Place Charlotte, North Carolina 28207 J. Michael McGarry, III, Esq.

Debevoise & Liberman 1200 Seventeenth St., N.W.

Washington, DC 20036

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Robert 6 uf Attorney fo W lmetto [ Alliance

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