ML20079P733
| ML20079P733 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/27/1984 |
| From: | Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8401310329 | |
| Download: ML20079P733 (5) | |
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s 00CKETED USHRC January 27, 1984 T4 JM 30 A11 d5 hy y n...
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DMMM Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA
) ASLBP 83-491-04-OLA (Three Mile Island Nuclear
) (Steam Generator Repair)
Station, Unit No. 1)
)
LICENSEE'S OBJECTIONS TO TMIA'S REQUEST FOR PRODUCTION OF DOCUMENTS i
On January 13, 1984, Licensee responded to TMIA's December 30, 1983 First Set of Interrogatories and Request for Production of Documents to Licensee.
Licensee made several significant concessions to TMIA with respect to the document request in order to ease and expedite the discovery process:
(a) in spite of the impermissibly broad scope of the document requests, Licensee agreed to make available virtually all of its files pertaining to the repair program to TMIA; (b) rather than have TMIA come to Licensee's offices in Parsippany, New Jersey, where the documents were located, as is the normal practice where large quantities of documents are requested, Licensee, at great effort and expense, established a discovery room in the vicinity of the plant site for TMIA's convenience, staffed and equipped to assist TMIA in locating and examining the files; and (c) Licensee went to great effort to make the documents 0401310329 840127 PDR ADOCK 05000289 O
PDR I
o available immediately, on January 18, rather than wait for January 29, the date after which production is due.
At the same time, Licensee retained its right to object.
Licensee herein, within the time permitted by 10 C.F.R.
S 2.741 (d),
objects to TMIA's production request No. 22.
Request No. 22 broadly seeks all documents which contain proprietary information.
No attempt was made to specify particular subject matters or relate them to any particular contention.
In the spirit with which Licensee has made available the bulk of its documents without objecting on grounds of relevancy or scope, Licensee had assumed that TMIA, in ac-cordance with customary practice, would agree to maintain the confidentiality of the information.
Not only has TMIA not agreed to protect the information, it has just filed a motion to comp 91 the production of documents under Request No. 22 without benefit of protective arrangements.
7 Accordingly, Licensee has no choice but to exercise its right at this time to object to Request No. 22 on the grounds
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that.it is overly broad and nonspecific, that it fails to identify the particular documents or subject matter requested, and that it exceeds the scope of the admitted contentions and the subject matter of this proceeding.
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'* Licensee's response to TMIA's motion to compel will be forthcoming.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
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/M By GForge F N rowbridge, P.C.
Bruce W. Churchill, P.C.
Diane E. Burkley Wilbert Washington, II Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
January 27, 1984 i
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e 00CMETED USHRC
'84 JAS 30 A11:25 UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION
,rrte: nr U CFa.lAn Before the Atomic Safety and Licensing Board UCC/5TINIE SEPVP '
dilAMC!!
In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 3)
)
CERTIFICATE OF SERVICE This is to certify that copies of " Licensee's Objections to TMIA's Request for Production of Documents ' are being served i
to all those on the attaened Service List by deposit in the United States mail, first class, postage prepaid, this 27th day of January, 1984.
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u)J m
L Bruce W. Wurchill, P.C.
Dated:
January 27, 1984
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety a.nd Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
SERVICE LIST Sheldon J. Wolfe Atomic Safety and Licensing Administrative Judge Board Panel Chairman, Atomic Safety and U.S.
Nuclear Regulatory Commission Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Docketing and Service Section (3)
Washington, D.C.
20555 Office of the Secretary U.S.
Nuclear Regulatory Commission Dr. David L.
Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Joanne Doroshow, Esq.
Professor of Nuclear Engineering Louise Bradford University of Arizona Threc Mile Island Alert, Inc.
Tucson, Arizona 85271 315 Peffer Street Harrisburg, Pennsylvania 17102 Dr. James C.
Lamb, III Administrative Judge Jane Lee Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill, North Carolina 27514 Norman Aamodt Richard J.
Rawson, Esq.
R. D.
5, Box 428 Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555
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