ML20102C331

Motion to Compel Discovery of NRC Staff Re Contention 41-G Concerning Treatment of C Van Vo by Cp&L.Certificate of Svc Encl.Related Correspondence

ML20102C331
Person / Time
Site:	Harris
Issue date:	03/01/1985
From:	Eddleman W, Eeddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-883 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8503050514
Download: ML20102C331 (2)

Text

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u trEn UNITED STATES OF AMERICA -

1MNch1985 NUCLEAR REGULATORY COMMISSION '65 MR -5 All :11 yy.;L:: scu c.-

BEFORE THE ATOMIC SAFETY AND LICENSING BOAWDMSEEV'CL Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unit 1) ) ASLBP No. 82-h68-01

) OL Motion to Compel Discovery of NRC Staff On 4 February 1985 Wells Eddleman filed discovery of NRC Staff on Contention 41-G, seeking information concerning the concerns raised by Chan Van Vo and information concerning the treatment of Chan Van Vo by CP&L. Staff counsel has advised me that no answers to these interrogatories and requestfor production of documents will be forthcoming. We were unable to resolve this issue in oral negotiations; therefore this Motion to Conpel ic filed.

(Since this Motion is filed within ten days of the default answer date of February 25, 1985 -- Feb. 4 plus 19 days, carried to next work .

day, no separate notice of negotiations is needed or made.)

I am aware of the Office of Invesitigations (OI) letter to the Board stating that OI's inquiry into these matter,s may take another ten weeks. I have no objection to letting OI nrovide information gx responsive to the Feb 4 interrogatories after they finish investigating.

8 However, OI is not all of the NBC Staff. I understand no answers or objections were timely filed February 25 (none have been received) and k

og therefore I move to compel answers by the Staff as soon as possible, since it appears I will need Staff's (I&E and other parts of the NRC Staff other than OI) responses and information to respond to sumnary ends to file.

dispositionwhichIbelievethepowercoganyiny/

This is the first day of March, 1985. h/ N /**4-

} wells.Eccleman

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UNITED STATES OF AMERICA NUCLTAR REGUIATORY C0!S3.ISSION In the matter or CAROLHA POWER 4 LIGHT C0. Et al. ) Docket 50-h00 Shearon Harris Nuclear Power Plant. Unit 1* _. ) 0.L.

Motion for Reconsiderat'on on CERTIFICATE 0F SERVICE 57-C-7,to E plan sewvees & all; n M el disc very f NRC Staff, l I hereby certify that copies of and of WE Responses to An">11 cants' Interrogatories on kl.0 & to Re9uest

_for oroduct_ ion _of documanu9 on Mn )

HAVE been served this 1 day of March 1981 , by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are arked with an asterisk, for whom service was accomplished by also serving a copy of the interrogatory responses on Andy McDaniel of CP&L Legal Dept, Box 1551, Raleigh NC 27602.(Trowbridge still served too.)  !

Judges Jates Ke11ev, Glenn Bright and Jae.as Carpenter (1 e g y each)

Atenic Safety and Licensing Board US Nuclear Megulatery Connission Washington DC 20555

• George F. Trowbridge (attorney for Applicants)

Shaw, Pittnan, Potts & Trowbridge R uthanne G. Miller 1600 M St. W ASLB Panel Washington, DC 20036 USNRC Washington DC 2055 5 Spence W. Perry Office of the Executive Legal Directer [ "

Attn Docke ts 50-400/401 0.L.

USNRC 014,4 U

up9

$ cst *8" Washingt n DC washington DC 20555 20740 Dan Read Docketing and Service Section (3x) CEA?tT/TLP i

Attn Docke ts 50-h00/LO1 o.L. .

i Office of the Secretary Waleigh,rt07 Waveross NC 27606 j USNRC Dr. Linda W. Little Washington DC 20555 Governor's Waste Mgt. Bd.

(E plan only) 513 Albenarle B1dg.

John Runkle Steve Roch1 mis 325 N. Sal' abut v St.

CCNC FEI'.A-Suite 700 Raleigh, NC 27611 307 Granville Rd 137.1 Peachtree St.NE -

Chapel Hill Ne 2751L Atlanta GA 30309 Bradley W. Jones I

Robert Gruber USNRC Region II

( Travi s Payne Exec. Director 101 Marietta St.

Idelstein & Payne Public Staff Atlanta GA 30303 l Blex 12601 Box 991 i Raleigh NC 27608i Raleigh NC 27602

! Richard Wilson, M.D. Certified by w 729 Hunter St.

Apex NC 27502

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