ML20063M195
| ML20063M195 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/03/1982 |
| From: | Guild R GUILD, R., PALMETTO ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20063M202 | List: |
| References | |
| NUDOCS 8209100180 | |
| Download: ML20063M195 (2) | |
Text
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00LKETED USNRC
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mjuT.3 UNITED STATES OF AMERICA
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NUCLEAR REGUIRIORY CCMCSSION 12 SEP -7 NO :45 BEFORE THE A'IOMIC SAFEIY AND LICENS1NG BOARD In the Matter of
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BRANCH DUKE POWER COMPANY, et al.
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Docket Nos. 50-413
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50-414 (Catawba Nuclear Station,
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Units 1 and 2)
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PAI1EI'IO ALLIAtCE M7 TION 'IO REQUIRE STAFF ANSWERS 'IO INTERROGA'IORIES Pursuant to 10 CFR Section 2.720(h) (2) (ii), InterVenor Palmetto Alliance herewith files the attached Second Set of Interrogatories and Requests to Produce with the Licensing Board which are served on the Applicants and Cmmission Staff including the Executive Director for Operation.
Intervenor requests that the Cmmission Staff voluntarily answer the interrogatories and serve upon Intervenor copies of the documents of which production is sought.
If such voluntary responses by Staff are refused, Palmetto Alliance moves for an order directing the Staff to answer on the grourx'.s that answers to these interrogatories are necessary to a proper decision in this proceeding and that, in scme part not now fully known to Intervenor, answers to the interrogatories are not reasonably obtainable frun any other source.
Palmetto Alliance further requests that the Board direct or " urge", as appropriate, the Staff to make "as much effort as possible...to assist the intervenors in obtaining the relevant information they seek to develop their positions to the fullest possible extent," as approved by the Appeal Board in Pennsylvania Power and Light Cmpany, et al., (Susquehanna Steam Electric Station, Units 1 and 2), AIAB-613,12 NRC 317 at 336 (1980), to include such 1
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measures as "lendinr: documents and transcripts to intervenor's representatives, giving than extra copics unneeded by staff, and setting up an additional local Public Document Rom...where the... representatives reside - sme 100 miles distant fran the plant site."
Id.
In support of this Mation and Request Palmetto Alliance asserts that it is a not-for-profit mmbership organization with extrmely limited financial resources, that it can not afford to purchase the transcript of this proceeding or to travel to the NRC Public Document Rom in Washington, D.C., to inspect Ca: mission documents, that its representatives reside and work sme 75 miles frm the facility, in Columbia, South Carolina and that inspection of documents and research in the local Public Document Rom in Rock Hill presents a signi-ficant hardship on this Intervenor.
Intervenor is informed that the only documents which will be available in the newly established " mini" document roan in Columbia will be Applicants' FSAR, ER and Application.
MEPEEDRE, Palmetto Alliance respectfully requests that the Staff j
voluntarily respond to this discovery or that the Board direct Staff response and urge assistance as herein described, and that the Board grant such further relief as is just and reasonable.
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Septmber 3, 1982
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Robert Guild 314 Pall Mall Columbia, South Carolina 29201 '
Counsel for Palmetto Alliance l
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