Motion to Overrule Callaway County Administrative Judge, RG Wright,820707 Objections to Interrogatories & Discovery Requests.Objections Pose Potential Delay in Events Leading to Oct 1982 Hearing.Certificate of Svc Encl| ML20055B103 |
| Person / Time |
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| Site: |
Callaway  |
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| Issue date: |
07/08/1982 |
|---|
| From: |
Jeffrey Reed
REED, J.G. |
|---|
| To: |
Atomic Safety and Licensing Board Panel |
|---|
| References |
|---|
| ISSUANCES-OL, NUDOCS 8207200362 |
| Download: ML20055B103 (4) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212K8711999-09-30030 September 1999
Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirements for Noncombustible Fire Barriers Penetration Seal Matls
ULNRC-04117, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.731999-09-22022 September 1999
Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.73
ML20217M2091998-03-19019 March 1998
Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds Amended Requirements. NRC Justification for Avoiding Backfit Analysis,Nonstantial.Backfit Analysis,As Required by Law as Mandatory for Proposed Rule Changes
ML20217J9691997-10-16016 October 1997
Order Approving Application Re Corporate Merger Agreement Between Union Electric Co & Cipsco,Inc to Form Holding Company.Commission Ordered to Approve Subj Application
ML20148N0511997-06-19019 June 1997
Comment Opposing Proposed NRC Bulletin 96-001,Suppl 1, CR Insertion Problems
ML20140G1691997-06-0606 June 1997
Requests Extension of Comment Period Expiration Date from 970619 to 970719,for Comments on Control Rod Insertion Problems
ML20077E9041994-12-0202 December 1994
Comment Supporting Proposed Rule 10CFR50 Re TS Improvements. Advises That PSA Portion of Fourth Criterion Should Be Clarified to Include Only Those Equipment Items Important to risk-significant Sequences as Defined in GL 88-20,App 2
ML20071L1951994-07-21021 July 1994
Comment on Proposed Rule 10CFR26 Re Changes to fitness-for-duty Requirements.Urges NRC to Revise Scope of 10CFR26 to Limit Random Drug & Alcohol Testing to Only Workers Who Have Unescorted Access to Vital Areas at NPP
ML20065D3851994-03-22022 March 1994
Comment on Draft NUREG-1022, Event Reporting Systems, 10CFR50.72 & 50.73
ML20113H4281992-07-23023 July 1992
Comment Commending Proposed Suppl One to GL 83-28 4.2.3 & 4.2.4 Closing All GL 83-28 Actions for Callaway But Staff Conclusion Should Be Expanded
ML20101P4091992-06-26026 June 1992
Comment Supporting low-level Radwaste After Treatment to Reduce Volume & Represents Safest,Most Cost Effective Solution
ML20091F9501991-12-0202 December 1991
Submits Comments Opposing Draft NUREG-1022, Event Reporting Sys,10CFR50.72 & 50.73. Licensee Feels That Changes to Intial NUREG-1022 Increases Util Expenses W/O Improving Public Health & Safety
ML20058D2741990-10-15015 October 1990
Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal
ML20058N9891990-08-0101 August 1990
Comment Re Proposed Rules 10CFR20,30,40 & 70, Notifications of Incidents. Language of Rule Should Be Clarified by Referring to Applicable Reporting Requirements of 10CFR50.72 & 73 for Commercial Nuclear Power Reactors
ML20063Q1771990-07-0606 July 1990
Comment on Petition for Rulemaking PRM-50-55 Re Revs to Fsar.Revs Should Be Driven by Circumstances Rather than by Arbitrary Time Schedule
ML20235V9301989-02-27027 February 1989
Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Endorses NUMARC Comments.Major Concern Is Lack of Demonstrated Need for Rule Since Most Utils Already Have Effective Maint Programs
ML20235T7901989-02-20020 February 1989
Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Establishment of Programs for Operators to Earn Degress Would Be Expensive
ML20235T7011989-02-17017 February 1989
Comment Opposing Proposed Rules 10CFR50 & 55 Which Require Degrees of Senior Operators & Shift Supervisors.Both Alternatives Would Contribute to Lower Morale Among Reactor Operators
ML20195J3191988-11-25025 November 1988
Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Policy of Yearly Testing & Testing for Cause,Backed Up by Training for Drug Prevention Supported
ML20195E8561988-10-28028 October 1988
Comment Supporting Proposed Rule 10CFR50 Re Renewal of Licenses
ML20133B7711985-08-0202 August 1985
Response to 850705 Petitioner Response in Opposition to Util Request That Show Cause Order Not Be Issued.Util Actions Demonstrate Dedication to QA & Safe Plant Operation. Certificate of Svc Encl
ML20128K2111985-07-0505 July 1985
Response Opposing Util Request That Show Cause Order Not Be Issued.Requests NRC Independent Investigation & Suspension or Revocation of OL During Period of Investigation
ML20129H7511985-06-0606 June 1985
Response to Missouri Coalition for Environ & K Drey 850325 Show Cause Petition Requesting Suspension or Revocation of OL Due to Questionable QC Inspector Certification.Denial of Petition Recommended.Certificate of Svc Encl
ML20129H7741985-06-0505 June 1985
Affidavit of DF Schnell Re Issues Raised in Missouri Coalition for Environ & K Drey Petition to Show Cause Requesting Suspension or Revocation of Ol.Root Causes of Questionable QC Certifications Addressed
ML20100F4301985-03-25025 March 1985
Show Cause Petition Requesting Suspension or Revocation of License NPF-30,due to Failure to Comply W/Qa Regulations & Guidelines Re Proper Training of QA Personnel
ML20092H1141984-06-22022 June 1984
Answer Opposing Petitioners 840613 Instant Motion for Order Setting Aside or Staying Permit for Ol.Certificate of Svc Encl
ML20197H4321984-06-13013 June 1984
Motion for Commission Order Setting Aside Low Power Testing Permit Granted on 840611,or in Alternative,Stay to Permit & Prohibit Taking of Any Action.Certificate of Svc Encl
ML20091R6401984-06-13013 June 1984
Request That Commission Enter Order Setting Aside Low Power Testing Permit Allegedly Granted on or About 840611,due to Joint Intervenors 840418 Motion for Leave to File Supplemental Contention
ML20084G1561984-05-0303 May 1984
Answer Opposing Coalition for Environ,Missourians for Safe Energy & Crawdad Alliance 840418 Motion for Leave to File Supplemental Contention Re Financial Qualifications of Util. Certificate of Svc Encl
ML20084G1791984-05-0303 May 1984
Affidavit of Cw Mueller Re Financial Integrity of Util
ML20084G1731984-05-0202 May 1984
Affidavit of DF Schnell Re Financial Stability of Util
ML20083Q3671984-04-18018 April 1984
Supplemental Contention Re Applicant Financial Qualification to Construct & Operate Facility.Certificate of Svc Encl
ML20083Q3521984-04-18018 April 1984
Motion for Leave to File Supplemental Contention Re Financial Qualification of Applicant to Construct & Operate Facility.Certificate of Svc Encl
ML20083Q2601984-04-18018 April 1984
Notice of Appearance of LC Green & Withdrawal of KM Chackes as Counsel for Intervenors.Certificate of Svc Encl
ML20082A6631983-11-15015 November 1983
Comments on NRC & Applicant Responses to Aslab 831020 Order Requesting Addl Info.Responses Contain Nothing More than Description of Activities & Conclusion of No Safety Significance.Certificate of Svc Encl
ML20082B4641983-11-15015 November 1983
Comments on Applicant & NRC Responses to Aslab 831020 Memorandum & Order Re Safety of Manually Welded Embedded Plates.Appointment of Independent Expert Requested. Certificate of Svc Encl
ML20078P7131983-11-0404 November 1983
Response to Aslab 831020 Memorandum & Order for Addl Info on Observation 4-1 of Integrated Design Insp Program Rept Re Original Design Floor Response Spectra.Spectra Have No Safety Significance.Certificate of Svc Encl
ML20078P7251983-11-0303 November 1983
Affidavit of Ew Thomas Re Revised Design Response Spectra
ML20081C3031983-10-27027 October 1983
Reply to Reed 831006 Proposed Findings of Fact & Conclusions of Law Re Contention 6.Findings Mischaracterized Fda Recommendation & Position of Applicant & State of Mo. Certificate of Svc Encl
ML20078H1751983-10-12012 October 1983
Response to Joint Intervenors 830823 Petition for Reconsideration of ASLB 830914 Decision ALAB-740. Insufficient Showing Made to Justify Reopening Record. Certificate of Svc Encl
ML20080Q4471983-10-0606 October 1983
Findings of Fact & Conclusions of Law.Certificate of Svc Encl
ML20080M6381983-09-29029 September 1983
Motion for Extension to File,W/Commission,Petition for Review of Aslab 830914 Decision ALAB-740.Extension Should Be Granted Until 15 Days After Aslab Rules on Joint Intervenors 830923 Reconsideration Petition.Certificate of Svc Encl
ML20078B4981983-09-23023 September 1983
Petition for Reconsideration of 830914 Decision ALAB-740 in Light of New Evidence Re Adequacy of Applicant QA Program. Many Items Remain Open in Integrated Design Insp Program Rept.Certificate of Svc Encl
ML20078B8201983-09-23023 September 1983
Proposed Corrections to 830913 Evidentiary Hearing Transcript.Certificate of Svc Encl
ML20078B8151983-09-23023 September 1983
Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision
ML20024E8211983-08-31031 August 1983
Comments on Applicant Response to Aslab 830815 Order Re Failure to Provide Safe SA-312 Piping & Adequate QA Program.Certificate of Svc Encl
ML20080C6991983-08-24024 August 1983
Testimony of Ng Slaten in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence
ML20080C7141983-08-24024 August 1983
Testimony of Kv Miller in Response to Reed Contention 6 Re Protective Actions Against Radioiodines.State of Mo Decided Not to Administer Potassium Iodide to General Public Based on Federal Guidance & Weighing of Advantages/Disadvantages
ML20080C7121983-08-24024 August 1983
Testimony of Re Linnemann in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence
ML20080C7061983-08-24024 August 1983
Testimony of DF Paddleford in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence
1999-09-30
[Table view]
Category:PLEADINGS
MONTHYEARML20133B7711985-08-0202 August 1985
Response to 850705 Petitioner Response in Opposition to Util Request That Show Cause Order Not Be Issued.Util Actions Demonstrate Dedication to QA & Safe Plant Operation. Certificate of Svc Encl
ML20128K2111985-07-0505 July 1985
Response Opposing Util Request That Show Cause Order Not Be Issued.Requests NRC Independent Investigation & Suspension or Revocation of OL During Period of Investigation
ML20129H7511985-06-0606 June 1985
Response to Missouri Coalition for Environ & K Drey 850325 Show Cause Petition Requesting Suspension or Revocation of OL Due to Questionable QC Inspector Certification.Denial of Petition Recommended.Certificate of Svc Encl
ML20100F4301985-03-25025 March 1985
Show Cause Petition Requesting Suspension or Revocation of License NPF-30,due to Failure to Comply W/Qa Regulations & Guidelines Re Proper Training of QA Personnel
ML20092H1141984-06-22022 June 1984
Answer Opposing Petitioners 840613 Instant Motion for Order Setting Aside or Staying Permit for Ol.Certificate of Svc Encl
ML20091R6401984-06-13013 June 1984
Request That Commission Enter Order Setting Aside Low Power Testing Permit Allegedly Granted on or About 840611,due to Joint Intervenors 840418 Motion for Leave to File Supplemental Contention
ML20084G1561984-05-0303 May 1984
Answer Opposing Coalition for Environ,Missourians for Safe Energy & Crawdad Alliance 840418 Motion for Leave to File Supplemental Contention Re Financial Qualifications of Util. Certificate of Svc Encl
ML20083Q3521984-04-18018 April 1984
Motion for Leave to File Supplemental Contention Re Financial Qualification of Applicant to Construct & Operate Facility.Certificate of Svc Encl
ML20078P7131983-11-0404 November 1983
Response to Aslab 831020 Memorandum & Order for Addl Info on Observation 4-1 of Integrated Design Insp Program Rept Re Original Design Floor Response Spectra.Spectra Have No Safety Significance.Certificate of Svc Encl
ML20078H1751983-10-12012 October 1983
Response to Joint Intervenors 830823 Petition for Reconsideration of ASLB 830914 Decision ALAB-740. Insufficient Showing Made to Justify Reopening Record. Certificate of Svc Encl
ML20080M6381983-09-29029 September 1983
Motion for Extension to File,W/Commission,Petition for Review of Aslab 830914 Decision ALAB-740.Extension Should Be Granted Until 15 Days After Aslab Rules on Joint Intervenors 830923 Reconsideration Petition.Certificate of Svc Encl
ML20078B4981983-09-23023 September 1983
Petition for Reconsideration of 830914 Decision ALAB-740 in Light of New Evidence Re Adequacy of Applicant QA Program. Many Items Remain Open in Integrated Design Insp Program Rept.Certificate of Svc Encl
ML20076G9071983-06-13013 June 1983
Answer to Jg Reed 830531 Motion & Response to Applicant Motion for Summary Disposition of Jg Reed Contentions. Temporary Funding of Gw Stanfill Position Irrelevant & Accusation of Bias W/O Foundation.Certificate of Svc Encl
ML20023D8041983-05-31031 May 1983
Motion & Response to Applicant 830520 Motion for Summary Disposition of Jg Reed Contentions 1 Through 11 & 13 Through 20.Applicant Motion Should Be Denied Since Matl Facts Should Be Heard.W/Certificate of Svc
ML20071J0491983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 20 on Authorization of Excess Radiological Worker Exposures & Spec of Decontamination Action Levels
ML20071J0441983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 20 Re Authorization of Excess Radiological Worker Exposures & Spec of Decontamination Action Levels.No Genuine Issue of Matl Fact Exists & Util Entitled to Favorable Decision
ML20071H9861983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 19 on Impediments to Use of Evacuation Routes
ML20071H9781983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 19 Re Impediments to Use of Evacuation Routes.No Genuine Issue of Matl Fact Exists & Util Entitled to Favorable Decision
ML20071H9741983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 18 on Human Food & Animal Feeds
ML20071H9721983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 18 Re Human Food & Animal Feeds.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H9521983-05-20020 May 1983
Statement of Matl Fact as to Whcih There Is No Genuine Issue Re Reed Contention 17 on Radiological Monitoring
ML20071H9451983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 17 Re Radiological Monitoring.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H9271983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Contention 15 on Ltrs of Agreement
ML20071H9061983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 15 Re Ltrs of Agreement.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H9041983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Contention 14 on Incorporated Cities,Towns & Villages
ML20071H8881983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 14 on Incorporated Cities,Towns & Villages.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H8641983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 13 on Organizations Requiring SOPs
ML20071H8521983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 13 Re Organizations Requiring Sops.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H8151983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 11 on Recovery & Reentry Radiation Stds
ML20071H8011983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 11 Re Reentry/Recovery Radiation Stds.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H7831983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 10 on Medical Treatment
ML20071H7731983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 10 Re Medical Treatment.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H7531983-05-20020 May 1983
Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 9 on Radiological Exposures
ML20071H7501983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 9 on Radiological Exposures.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H7181983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 8 on Radiation Detection Equipment
ML20071H7081983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 8 Re Radiation Detection Equipment.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H6871983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 7 on Presited Decontamination Facilities
ML20071H6711983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 7 Re Presited Decontamination Facilities.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H6141983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contentions 6 & 16 on Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering
ML20071H6041983-05-20020 May 1983
Motion for Summary Disposition of Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages for long- Term Sheltering.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H5821983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 5,Parts B & C on Radio Communications
ML20071H5771983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 5,Parts B & C Re Radio Communications.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H5631983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 4 on Emergency Action Level Scheme/ Worker Notification
ML20071H5531983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 4 Re Emergency Action Level Scheme/Worker Notification.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H5221983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 3 on Emergency Mgt Director Staffing
ML20071H5181983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 3 Re Emergency Mgt Director Staffing.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H5041983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 2 on Staffing of County Clerk Ofcs
ML20071H4961983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 2 Re Staffing of County Clerk Ofcs.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20071H4251983-05-20020 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 1 Staffing of Montgomery County Sheriff Ofc
ML20071H4151983-05-20020 May 1983
Motion for Summary Disposition of Reed Contention 1 Re Staffing of Montgomery County Sheriff Ofc.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
1985-08-02
[Table view] |
Text
_ . . .
5 t
,t UNITED STAThS OF APrRICA DOUma NUCLEAR REGULA10hY CO:713S10N :P J #
- C2 a 19 P!2:D BhJCid THE ATOMIC SAFhTY AND LICERSING BOARD
- p. _ p .:. -
In the Matter of
)
) . ,~,4 UNION ELECTRIC COMPANY ) Docket Nr. S'm 50-483 OL
)
(Callaway PJant, Unit 1) )
MMION TO OVEP.RLL; 03'hCTIONS OF ROBERT G. WRIGHT, DATED 07 July 1982, The undersigned, on 01 July 1982, moved that the Board compel Callaway County and the State of Missouri to respond to discovery requests which had been initiated by said undersigned. The State of Missouri, through the offices of A. Scott Cauger, Esquire, Assistant General Counsel for the Missouri Public Service Connission has begun such response. Mr. Robert G. Wright, objects to being required to comply with discovery. It is respectfully noved that the Board overrule such objections and compel Mr.
Wright, the official representattve of the Callaway County Court, to comply with discovery.
DISCUSSION Pr. Wright was duly elected to office as Associate Adirdnistrative Juige of Callaway Co'inty on 04 Nove'r.ber 1980. He petitioned, under the provisions o f 10 CF.n. , Part 2, Section 2.715(c) to represent callaway County in this matter as pertains to issues of public health and safety or environment.
His representative authority was formally authenticated on 18 Februar/-
1941 in "Mr. Wrights Answer to Staff Response, dated 28 January 1981, a' tachrents 1 and 2". Mr. .iright was granted intervenor status by Board order of 05 Februe.r/ 1981. His I.artteipatory authority for the C.J! way Jounty Cuart was cuch that he cou3d act f:r the Presi<iing Judge 8207200362 820708 PDR ADOCK 05000483 y5 "- y G PDR
Jn all issues "reser ted re.a 1 ' d the affiel.a 'i.4pnort of the Prea ' d* ur, . t Ju l,3 . ! the A n <m el:.L c .h a t ;. ( f t.Le Jr st.i rn a1.st: c t. .
a duly eler:t'd county of t" ca ni and reprecent >tive sf the c unty, J'4.lge (Mr.) Wrl6 ht has the .P.hority to cc,rpl n cou.it;r employee (Llo Cr'].way Ccunty i:.mergency F;nagerent Cooriinator) to untwer interrogatories which relate to matters deniir.r with public ben]th en 18 fety or environment in the airve e ptioned mdter. Fr. ~.iright, wi th s Aid .uthority, is hirnsel f l e::.rowere'l to reapand to su h ir.te.roFtories trd hin ansacra will reflect the opinion of the entire Ca .nty Court.
Un.ler the toma of 10 CFF., 2.715(c) r. preentrtivoc of interested governr.ents h:wo powers c>_ceedint, thone (;ran te i under 2.71'/,a) . Jeh correnent:..tiv- n
' "/ I .t ro 'uc e ev?.denct, interrr; ..to dtn cco, Ovice the Gotr.lusion, file proposed fie li ry;n and except.iv. ' r.a r":Li tic n: for rovie.1 b;f the Cor.iscion, ach brc d , ithority and the gr:nt.ir.g of " int.ervcnor" atr.tus by the 3 cord
( rder of 05 Febru'try 1981, r.:rd:ca .ir. .right a party to the above captioned ther in fact, if not in lt.w. <.s ',uch !'r. .ri ght 's objections to providing infor natiert under the ter .r. of liscovery, when he i t authorized to intrcduce
- .ach inf,r'. ntion as cited r.bovc, trc without crit and tend to in:pede the 4 cewilr* ion af evidence by the underaigned and preprration fer the hearing cche luled in Cctober, this y* ar.
Pr. heed ir a.mre of his atth".rlty *.o snel: cuch infor, ..t. ion by subpoer.a, under the nrwiniens of 10 22., 2.740(f)(3). Suct action wiH be taken i ^ i nst re s >rt , if the rm,ucst od infor.wtior. c "not be obtid r ed oth':r.d se.
l l
SUMARY I'.r. Reed has requested infoncation undcr the provisions of discovery from the State of Missouri and the Collaway County Administrative Court.
The Statn of Missouri in responding to such request. The Cc03 away County Administrative Court (through I'e . Wright) refuses to respond and objects to being compelled to provide said information. Fr. Wright is a duly elected official of Callaway County, formally empowered by the County Court to represent them at hearings in this mtter, was granted intervenor status by the Board, has power to introduce evidence, interrogate witnesses, etc. , and the Callaway County Court, which he is a member and representative in this matter, is the sole source of the information requested. Mr. Reed feels that F.r. Wright's objections are intended to impede access to the requested information, thereby posing a potential for delay in the schedule of events which lead to the hearing in October 1982 For the above reasons, it is respectfully moved that the Board overrule Mr. Wright's objections and require the Callaway County Administrative Court Judges and the Callaway County Emergency !hnagerent Coordinator to answer the interrogatories posed by the undersigned. ,
e-cectfully submitted, Dated thin 08th day ochn G. Reed of July 1982, at Citizen of the United States Kingdom City,10. of America RFD //l Kingdom City, Missouri 65262 tcl: (314) 642-2769
UNITED tiTATF.S er' s.Md.ICa i . NUCLEAR kr4ULA10RY COMMIS': ION l
l BEFORE THE ATOMIC SAFE *l Y AND LIC.:r.21tJG BOAKD in t.Le Fatter of )
)
UNim sLECTiiIC CO}fANY ) Docket No. STN 50-483
)
(Callaway Plant., Unit 1) )
CERTIFICATE OF CENVICE I hereby certif that the docurrent attached hereto was served this 14 #h day of
, f ,1982 by deposit in the u.S. rnail, first class postage prepaid upon the following:
Jarr.es P. Gleason, Esquire Mr. Glenn O. Bright Chainnan, Atomic Safety and Ator:d o Safety and Licensing Board Licensing Boani Panel Panel 513 Gilrnoure Drive U.S. Nuclear Regulatory Corrrassion Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Servico Section Atcraic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory Cormission U.S. Nuclear Regulatory Cor. mission Washington, D.C. 20555 Knshington, D.C. 20555 Roy P. Lessy, Jr., Esquire Kenneth M. Chackes, Esquire Office of the Executive Legal Director Chackes and Hoare U.S. Nuclear Regulatory Cornission 316 N. Broadway Washington, D.C. 20555 St. Louis, P0. 63102 A. Scott Cauger, F squire Thomas A. Baxter, Esquire Assistant General Counsel Shaw, Pittman, Potts & Trowbridge H0 Public Service Consnission 1800 M. S t reet , N .W. P.O. Box 360 Washington, D.C. 20036 Jefferson City, MO. 65102 Atomic Safety and Licensing Robert Wright, Judge Eastern Dist.
Appeal So trd Callaway County Court U.S. Nuclear Regulatory Con.nission County Courthouse Washirigton, D.C. 20555 Fultcm, Missouri 65251 d ohn G. Feei A/ '
Citizer. c.f' the United States cf Arsr:ca
';4.t