ML20096B535
| ML20096B535 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/28/1984 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | Blake E SHAW, PITTMAN, POTTS & TROWBRIDGE |
| Shared Package | |
| ML20096B532 | List: |
| References | |
| SP, NUDOCS 8409040182 | |
| Download: ML20096B535 (1) | |
Text
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RELATED CCRRESPONDENCE
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HARMON, WEISS & JORDAN 2001 S STREET. N.W.
6.
SulTE 430 1
WASHINGTON, D.C. sooos 00CKETED H_ONE '
G All McGREEVY HARMON LE ELLYN R. WEISS (202)328 3500 WILLIAM S. JORDAN, lli h [% }j O!ANE CURRAN
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DEAN R. TOUSLEY s
August 28,'1984
.r,r.
Ernest Blake, Jr. Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Re:
GPU Interrogatories, TMI-l Restart
Dear Mr. Blake,
On August 21, 1984, I received your first set of interrogatories and document requests to UCS.
You state that you " assume" that UCS's response "will reflect the collective knowledge of any intervenor who has an interest in or desires to participate" in the covered areas of training.
You ask us to inform you if licensee is " incorrect in its assumption."
This is to inform you that UCS's responses will reflect UCS's knowledge regarding the issues in question.
While the agreement on lead intervenors anticipates that UCS will act as lead during the hearing on some training issues, and we are in fact cooperating with other parties during discovery, particularly to prevent insofar as possible serving duplicative requests on GPU, UCS does not have'the resources nor is it obliged under any order to answer discovery requests with any but UCS's own knowledge.
The intervenors maintain their independent party status in this case as I am sure you are aware, just as GPU and the NRC staff-do.
Very truly yours, Ellyn R. Weiss cc:
TMI-l licensing Board Service List ERW:nf 8409040182 840830 PDR ADOCK 05000289 G
PDR 4
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