ML20095E950
| ML20095E950 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/23/1984 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| SP, NUDOCS 8408270115 | |
| Download: ML20095E950 (6) | |
Text
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August 23, 1984 UNITED STATES OF AMERICA DMMETC NUCLEAR REGULATORY COMMISSION U:iNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 ISO 24 A!0:46 In the Matter of
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- P METROPOLITAN EDISON COMPANY
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Docket No. 50-289C7(,
)
(Restart Remand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S REQUEST FOR AN EXTENSION OF TIME WITHIN WHICH TO ANSWER TMIA'S SECOND SET OF INTERROGATORIES TO GPU On August 13, 1984, intervenor Three Mile Island Alert (TMIA) hand-served on Licensee's counsel a Second Set of Interrogatories.
These comprehensive interrogatories, 75 in.
number (excluding subparts), all pertain to the training remand.
Answers to these interrogatories are due on August 27, 1984.
10 C.F.R. S 2.740(b).
Licensee also was hand-served with a second document production request on August 13, to which a written response is due on September 12, 1984.
l 10 C.F.R. 5 2.741.
Licensee has now completed its review of these discovery requests and has begun to prepare answers to the interrogatories, the vast majority of which Licensee expects to answer substantively, and not pose any objection to.
Licensee also has begun gathering the extensive documents requested by TMIA and expects to be able to meet the September 12 document 8408270115 840823 PDR ADOCK 05000289 40g
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production response date.
However, it simply is not feasible for Licensee to meet the August 27 date for filing answers to TMIA's Second Set of Interrogatories.
Licensee relayed this information to TMIA's counsel on August 20, and requested an extension until September 12 to
-file its answers to the training interrogatories.
TMIA's counsel would not agree to this request without Licensee's agreement to extend the discovery period a like period of time, i.e.,
16 days.
Because Licensee is making every effort to facilitate the expeditious litigation of this remanded proceeding, Licensee would not agree to TMIA's request, which is not linked to any specific need by TMIA for further discovery beyond the current deadline of September 30.
Furthermore, Licensee notes that TM1A waited more than a month after the discovery period had begun before filing its Second Set of Interrogatories on Licensee.
See Memorandum and Order Following Prehearing Conference, July 9, 1984, at 9.
In such circumstances, it is unreasonable for TMIA to demand and expect an automatic extension of the discovery period (and, presumably, a delay in the scheduled evidentiary hearing) because Licensee cannot answer TMIA's extensive interrogatories on training within the time provided by the regulations.
Licensee therefore requests that the Board grant it an extension of time, until September 12, 1984, to answer TMIA's Second Set of Interrogatories.
Licensee notes, in this regard, that while it will make every effort to meet this propsoed.__
deadline, a number of the interrogatories are directed at the Reconstituted OARP Review Committee.
The members of this Committee are extremely busy individuals; they also are located in various regions of the country.
Licensee takes this opportunity to inform the Board that it may be necessary for Licensee to request more time within which to answer the interrogatories directed at the Committee, although Licensee is not now making this request.
Respectfully submitted, s w /b(L ~
Ernest L.
- Blake, Jr.,
P.C.
Deborah B.
Bauser SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Counsel for Licensee Dated:
August 23, 1984 l
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.REUsTED CC;iiESFO?iDENCE, s
August 23, 1984 00tKETE?
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 AGO 24 NO:46 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD fl$h,w..:tG:.'5bD pt CH In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
)
(Restart Remand on Management)
(Three Mile Island Nuclear-
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Licensee's Request for an Extension of Time Within Which to Answer TMIA's Second Set of Interrogatories to GPU were served this 23rd day of August, 1984, by hand delivery to the parties identified with an aster-isk and by deposit in the U.S. mail, first class, postagc pre-paid, to the other parties-on the attached Service List.
L m A. /.nas Deborah B.
Bauser w
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP
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Restart (Three Mile Island Nuclear
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Station, Unit No. 1)
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Service List Administrative Judge
- Chairman, Atomic Safety &
Iva'n W.
Smith Licensing Board Panel-Chairman, Atomic Safety &
U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Chairman, Atomic Safety &
Licensing Appeal Board Panel Administrative Judge
- U.S. Nuclear Regulatory Sheldon J. Wolfe Commission Atomic Safety & Licensing Washington, D.C.
20555 Board U.S. Nuclear Regulatory Thomas Y. Au, Esq.
Commission Office of Chief Counsel l
Washington, D.C.
20555 Dept. of Environmental Resources 505 Executive House Administrative Judge
- P.O. Box 2357
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Gustave A. Linenberger, Jr.
Harrisburg, PA 17120 Atomic Safety & Licensing i
Board U.S. Nuclear Regulatory Washington, D.C.
20555 1
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Jack Goldberg, Esq.
Office of Executive Legal Dtr.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
9 Docketing & Service Section Ellyn R. Weiss, Esq.
Office of the Secretary William S. Jordan, III, Esq.
U.S. Nuclear Regulatory Harmon, Weiss & Jordan Commission 2001 S Street N.W.,
Suite 430 Washington, D.C.
20555 Washington, D.C.
20009 Mr. Norman Aamodt Lynne Bernabei, Esq.*
R.
D.
5 Government Accountability Coatesville, PA 19320 Project 1555 Connecticut Avenue Joanne Doroshow, Esq.
Washington, D.C.
20009 The Christic Institute 1324 North Capitol Street Washington, D.C.
20002 Ms. Louise Bradford TMI ALERT Mr. Henry D.
Hukill 1011 Green Street Vice President Sarrisburg, PA 17102 GPU Nuclear Corporation P.O.
Box 480 Administrative Judge Middletown, PA 17057 Gary J.
Edles, Chairman Atomic Safety & Licensing Michael F. McBride, Esq.
Appeal Board LeBoeuf, Lamb, Leiby & MacRae U.S.
Nuclear Regulatory 1333 New Hampshire Avenue, N.W.
Commission Suite 1100 Washington, D.C.
20555 Washington, D.C.
20036 Administrative Judge Michael W. Maupin, Esq.
John H.
Buck Hunton & Williams Atomic Safety & Licensing 707 East Main Street Appeal Board P.O. Box 1535 U.S. Nuclear Regulatory Richmond, VA 23212 Commission Washington, D.C.
20555 Administrative Judge Christine N. Kohl Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Washington, D.C.
20555 l
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