ML20079M595
| ML20079M595 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/25/1984 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8401270369 | |
| Download: ML20079M595 (3) | |
Text
T 0?jkj7ED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 14 ggg pg p In the Matter of
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00CHLIJNG & SLRvin ANCH METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Steam Generator Repair)
(Three Mile Island Nuclear
)
Station, Unit 1)
)
TMIA MOTION FOR EXTENSIONS OF TIME FOR FILING RESPONSE TO LICENSEE'S SECOND SET OF INTERROGATORIES, FOR FILING TMIq_
SECOND SET OF INTERROGATORIES TO LICENSES, AND FOR FIIING MOTIONS TO COMPEL Pursuant to 10 CRF 5 2.740 and 2.711, TMIA hereby requests three time extensions in the above captioned case.
TMIA was served with a second set of Licensee interrogatories on or about January 16, 1984.
At that time, TMIA also received Licen-sne's response to TMIA's first set of interrogatories.
It also received 22 documents frcm Licensee, four of which were confisgated on January 18, and later returned to TMIA on January 20.
- Further, Licensee has established a document room containing a large number of documents which are relevant to TMIA's contentions.
Because of the enormous amount of material which TMIA must now review, the difficulty of getting these documents to an expert, and the inconven-icnce of the discovery room, TMIA requests time extension not only of filing responses to Licensee's second set of interrogatories and G401270369 840125 PDR ADOCK 05000289 G
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.2-filing a second set of interrogatories based on this new evidence, but also in filing motions to compel regarding Licensee's response to TMIA Interrogatories.
TMIA requestsa time extension for all three items until February 27, 1984.
This will of course require a rescheduling of the seccnd prehearing conference.
First, TMIA is having great difficulty not only getting to the discovery room, but in finding a voldheer " expert" with enough free time to accompany TMIA to this room to interpret this information.
(See accompanying motion for appointment of special pane ).
Without an cxpert, this information is virtually meaningless.
There is no possible way this material can be reviewed by an expert in less than a month's time, particularly in light of Licensee's 10 cent per page copying fee.
TMIA operates on a shoestring budget, and simply can not afford to pay to have documents copied.
Thus, it is necessary that we find someone who can devote large chunks of time in this room.
So far, we have been unable to do so.
Second, for approximately the same reason, TMIA will need at least a month's time to prepare additional interrogatories for the Licensee.
In addition, without sufficient time and expertise to pro-pnrly review Licensee's response to TMIA interrogatories and requests for document production, it is virtually impossible to know if suffi-cient responses have been obtained.
Third, TMIA representative Joanne Doroshow will be out of the country for two weeks in February, making it extremely difficult for TMIA to prepare its case during this time, even if all relevant material were obtainable and understood by the end of January.
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3 Thus, TMIA requests that, in the absence of appointment of a special panel pursuant to the accompanying motion, the time be extended until February 27, 1984, for producing responses to Licensee's second interrogatory requests, a second set of interrogatories for Licensee, and any motions to compel which may be necessary in response to the substance of Licensee's interrogatory answers.
Respectfully, Three Mile Island Alert, Inc.
By
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oanne Doroshow Jcnuary 25, 1984 Louise Bradford 4
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