ML20086G560

Motion to Compel Discovery on Licensee First Set of Interrogatories & Request for Production of Documents to Joint Intervenors.Notice of Appearance for W Washington & Certificate of Svc Encl

ML20086G560
Person / Time
Site:	Three Mile Island
Issue date:	01/09/1984
From:	Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20086G531	List: ML20086G527 ML20086G543 ML20086G560
References
ISSUANCES-OLA, NUDOCS 8401120282
Download: ML20086G560 (5)

Text

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January 9, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA

) (Steam Generator Repair)

(Three Mile Island Nuclear )

Station,-Unit No. 1) )

LICENSEE'S MOTION TO COMPEL DISCOVERY ON LICENSEE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOINT INTERVENORS Pursuant to 10 C.F.R. S 2.740 (f) , Licensee Metropolitan Edison Company, et al., hereby moves the Atomic Safety and Licensing Board to compel _intervenors Norman Aamodt and Jane Lee

(" Joint Intervenors") to answer separately and fully each of the interrogatories propounded to Joint Intervenors in " Licensee's First Set of Interrogatories and Request for Production of Docu-ments to Joint Intervenors" dated December 15, 1983.

Responses to the interrogatories, which relate to Joint Intervenors' Contentions 1(2) , 1(3), and 1(5), were due on January 3, 1984. 10 C.F.R. S 2.740b(b). Joint Intervenors have filed no response. They have not petitioned for an exten-sion of time to respond, nor have they made any effort to contact counsel for Licensee regarding Licensee's discovery requests.

8401120282 840109 PDR ADOCK 05000289 O PDR

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b; The Board, in its Memorandum and Order of November 29, 1983, ordered that discovery be completed by no later than January 31, 1984. In accordance with that order, Licensee filed its first discovery request in sufficient time to enable the filing of follow-up interrogatories, should they prove necessary as a result of Joint Intervenor's answers to the first set of interrogatories. The follow-up discovery request will have to be filed no later than January 12 or January 17, 1984, depending on how service is made, if Joint Intervenors' responses are to be filed in time for completion of discovery by January 31, 1984.

-Accordingly, Licensee requests that the Board compel Joint Intervenors to immediately and fully answer Licensee's first set of interrogatories in a manner which will allow Licensee its right to full discovery, including supplementary requests, prior to January 31, 1984.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE T

' s 1,6 '

s uv GeMe Mrowbridge, 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 9, 1984

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA

) (Steem Generator Repair)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

NOTICE OF APPEARANCE The undersigned, being an attorney at law in good standing admitted to practice before the Courts of the District of Columbia, hereby enters his appearance on behalf of Metropolitan Edison Company,et al., in proceed-

'ings related~to the above-captioned matters.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

~

k >'t dh*J ' ,1Aw. .$.m Wilbert Washingto'n, II 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: January 9, 1984

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k UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the' Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA

) (Steam Generator Repair)

(Three Mile Island Nuclear )

Station, Unit No. 1) )-

CERTIFICATE OF SERVICE This is to certify that copies-of the foregoing

" Licensee's Motion to Dismiss Intervenor TMIA's Contentions 1.a, 1.b, 1.c and 2.b.1," " Licensee's Motion to Compel Discovery on Licensee's First Set of Interrogatories and Request for Pro-duction of Documents to Intervenor TMIA," " Licensee's Motion to Compel Discovery on Licensee's First Set of' Interrogatories and Request for Production of Documents to Joint Intervenors," and

" Notice of Appearance of Wilbert Washington, II" were served, by deposit in the United States Mail, firut class, postage pre-paid, to all those on the attached Service List, except that those marked with an asterisk were served by express mail through deposit with Federal Express, this 9th day of January, 1984. i I

e/

/ /

B p' W N 1urchill, P.'C.

Dated: January 9, 1984

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s. ,

s.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA

) (Steam Generator Repair)

(Three Mile Island Nuclear )

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 Three 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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