ML20065A989
| ML20065A989 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 02/17/1983 |
| From: | Reynolds N DEBEVOISE & LIBERMAN, WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20065A992 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8302220350 | |
| Download: ML20065A989 (3) | |
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00tKETED Applicant FebruaryiT7, 1983
'83 FEB 18 li9:48 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY A11D LICENSING BOARD In the Matter of-
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WASHINGTON PUBLIC POWER
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SUPPLY SYSTEM
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Docket No. 50-460-OL
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(WPPSS Nuclear Project No. 1)
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APPLICANT'S MOTION FOR LEAVE TO SUPPLEMENT MEMORANDUM On February 7, 1983, the Washington Public Power Supply System (" Applicant") filed its " Memorandum in opposition to 4
Issuance of a Protective Order. "
Memoranda on that subject also were filed on that date by the NRC Staff and the peti-tioner for intervention.
In its memorandum, petitioner stated that "the Applicant in this case has also subjected Petitioner's members [ sic) to harassment by exerting pressure upon him to withdraw his support from the petitions which were filed in early 1982."
(petitioner's memorandum, at 6).
Petitioner also asserted that "[w]hile he has not yet lost his present employment, such employment has been directly threatened by his associa.
~ tion with the organization" (Id.).
r302220350 830217 gDRADOCK 05000460
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t In view of this' serious charge by petitioner, counsel-
' for Applicant requested that the employee of Applicant o
(Wr.-Sorensen) who contacted the member of the pe_titioner (Mr. Dana) prepare an affidavit relating in detail the
' facts involving that contact.
A copy'of that affidavit is attached hereto.
The affidavit demonstrates that no pressure was placed upon Mr. Dana to withdraw his support of the petitioner and that no attempt has been made to imperil Mr'.
Dana's employment in any way.
Applicant hereby requests leave to amend its February 7 memorandum by including the attached affidavit.
It is im-portant that the affidavit become a part of the record in this proceeding so that the gross distortions of the truth by this petitioner are revealed, and that the record reflects the true and correct facts surrounding the contact.
In addition, Applicant requests that the Board take official notice, pursuant to 10 C.F.R.
S2.743(i), of pages 36-39 of the transcript of NRC proceedings in Puget Sound Power & Light Co. et al. (Skagit/Hanford Nuclear Project, Units 1 & 2), Docket Nos. STN-50-522 and STN-50-523, May 5, 1982.
A copy of that transcript is attached hereto.
Peti-l tioner read a portion of this transcript excerpt into the l
record during the January 26 and 27 Special Prehearing Conference, purportedly to show a basis for its claim of e
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harassment.
See Washington Public Power Supply System Nuclear Projects Nos. 1:and 2, Docket Nos. 50-397-CPA, 50-460-CPA, and 50-460-OL, Transcript of January.26 and 27 Prehearing Conference'at pages 39-40.
In fact, the transcript in Skagit/Hanford reveals that the Licensing l
Board there rejected petitioner's claim of harassment and indicated that petitioner's member had an obliga-tion to respond to a request for discovery propounded
'lar the applicants regarding standing.
We believe that the Skagit/Hanford Board's disposition of the matter provides useful guidance to this Board in view of the identical nature of the " harassment" claim raised by petitioner.
Respectfull submitted, N
h SanfordL.fReynolds Nichola S
F artman DEBEVO$5;E & LIBERMAN 1200 SMre enth Street, N.W.
Washington, D.C.
20036 (202) 857-9800 Counsel for Applicant February 17, 1983 4
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