ML20053E580

Reply Opposing Licensee 820528 Motion to Impose Sanctions & Strike Contentions.Answers to Interrogatories Depend on Info Which Only Licensees Can Supply

ML20053E580
Person / Time
Site:	Indian Point
Issue date:	06/04/1982
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20053E577	List: ML20053E576 ML20053E580 ML20053E583
References
ISSUANCES-SP, NUDOCS 8206090037
Download: ML20053E580 (2)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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l ATOMIC SAFETY AND LICENSING BOARD 5[

Administrative Judges:

'82 LM / All :10 Louis 3. Carter, Chairman Dr. Oscar H. Paris Frederick 3. Shon Ec.., j g' '.

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In thy Matter of

~. 4 - c i-j CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 50-247-SP l

(Indian Point, Unit 2) 50-286-SP i

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POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit 3)

WEST BRANCH CONSERVATION ASSOCIATION'S REPLY TO LICENSEES' MOTION TO IMPOSE SANCTIONS AND STRIKE CONTENTIONS Under date of May 28, 1982, Licensees forwarded by Express mail above captioned motion which arrived on May 30, a Saturday of Memorial Day weekend.

Had it been mailed in less expensive fashion it would have arrived on the next working day, Tuesday June 1.

Its contents are reflective of the same wasteful excesses shown by the Licensees throughout above captioned case.

It is untimely to question the contentions or the ASLB's Order of April 23 at this date.

The Board determined the nature of this proceeding well within its powers and the Commission's intent in setting up an investigatory procedure.

l Licensees are the sole repositroy of some of the infor-mation necessnrv for the Board to make a reasoned decision.

1. At $9.35 each, approximate total of $327.25.

. for West Branch Conservation Association, Inc.

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b 914/634-2327 bYZipporahS. Fleisher Secretarv 8206090037 820604 s

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PDR ADOCK 05000247 G

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WBCA's answers clearly depend on information which onlyg fi fi the Licensees could supply. Nor were they in any way capri-

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clous but had they received the timely and suitable Yeplies A11 :10

5 they deserved, we would have been f ar better prepared and not g

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still seeking information at this late date.

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Licensees motion states a blanket objection to UBCA's response and gives no specific information that they requested t:

and we failed to supply, within our powers, We have acted in good faith, we have anticipated deadlines and not played a brinkmanship game.

In fact, Licensees have failed to respond to many of our interrogatories timely filed on April 29.

It is not we who offered them documents to view 50 miles away and 6 days before testimony in-hand date.

It is Licensees who had two years and $7,000,000 to pre-pare their case and now they pick on a volunteer group which has had five weeks since being designated an intervenor and assigned contentions.

On the contrary, Licensees are sub-verting the proceedings and attempting to distract WBCA from its work.

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