ML20210A881

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Forwards Gpu Nuclear Corp Motion to Compel NRC to Produce Documents & Request for Oral Argument & Issuance of Subpoenas.Addl 2 Days (Until 870204) in Which to File Discovery Motion Approved by Presiding Officer
ML20210A881
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 02/04/1987
From: Jim Hickey
GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Smith I
Atomic Safety and Licensing Board Panel
Shared Package
ML20210A887 List:
References
CON-#187-2444 CIV-PEN, EA-84-137, NUDOCS 8702090034
Download: ML20210A881 (2)


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J. PATRICK HICKEY. P.C. (2 2)775 33.

February 4, 1987 Ivan W. Smith ,

Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of GPU Nuclear Corporation (Three Mile Island Nuclear ion, Unit 2)

Docket No. 50-320T 4-137 - cJ v PE d

Dear Judge Smith:

Enclosed please find "GPU Nuclear Corporation's Motion to Compel NRC Staff to Produce Documents and Request for Oral Argument" and "GPU Nuclear Corporation's Motion for Issuance of Subpoenas," which were filed today.

These motions are submitted within the time limits agreed to by GPUN and the NRC Staff and approved by Presiding Officer. In a conference call on November 4, 1986, the Presiding Officer approved the parties' agreement that the NRC Staff and GPUN need not file a motion to compel within the ten day period provided by the Rules of Practice, thereby enabling the parties to attempt informal resolution of their disputes. The parties further j agreed that in the event negotiations reached an impasse, the i parties would notify the Presiding Officer and motions to compel

! would be due ten days thereafter. See Letter From J. Patrick Hickey to G. Johnson (Nov. 4, 1986).

Negotiations have continued since that time and have produced some results. However, a number of disputes remain unresolved. On January 20, 1987, counsel for GPUN and counsel for the NRC Staff notified the Presiding Officer that they had reached an impasse. February 2, 1987 was set as the date by which motions to compel were to be filed. During this conference call, the Presiding Officer also approved an extension of the discovery schedule until May 1, 1987.

On February 29, 1987, with the consent of the NRC Staff, counsel for GPUN requested from the Presiding Officer an gh 8702090034 870204 PDR ADOCK 05000320

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  • SHAW, PITTMAN, PoTTs & TROWBRIDGE A PARTNER $848D INCLUOtNG PROrtSSsONAL COR80 RATIONS Letter to Ivan W. Smith, Esq.

February 4, 1987 Page 2 additional two days (until February 4) in which to file discovery motion, because of the number of days lost due to the recent snow storms. The Presiding Officer approved this request.

Sincerely,

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}{s avx O JV Patri k Hickpy Counsel for GPU lear Corporation cc: Service List