ML17272A269

Applicant Answer in Opposition to Petitioners Darby Garrett & Hanford Conversion Project Request for Waiver of 10CFR2.708(b).W/encl Certificate of Svc

ML17272A269
Person / Time
Site:	Columbia
Issue date:	01/19/1979
From:	Reynolds N DEBEVOISE & LIBERMAN
To:
References
NUDOCS 7901300024
Download: ML17272A269 (5)

Text

UNITED STATES OF, AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'7'f In the Matter of))WASHINGTON PUBLIC POWER)SUPPLY SYSTEM))(WPPSS Nuclear Project No.2))Docket No.50-397-OL APPLICANT'S ANSWER TO PETITIONERS'EQUEST FOR WAIVER OF 1'0:'C.F.R.

'52'.70'8'(b)'n a pleading dated January 10, 1979, petitioners Darby, Garrett and Hanford Conversion Project ("HCP")requested that, this Board waive that part of 10 C.F.R.52.708(b)which requires double spacing of the text of documents filed with the Board.The Washington Public Power Supply System (" Applicant")hereby opposes the'request for waiver of this Rule.While the rule might impose slightly higher costs on petitioners, the benefits of the rule clearly outweigh such costs.Single spaced documents such as petitioners'econd Amended Petition to Intervene dated.January 10, 1979, are difficult to read, reproduce, and telecommunicate.

For example, Applicant's counsel was unsucces'sful in attempting to telecommunicate to Applicant (from Washington, D.C.to Richland, Washington) the second Amended Petition because the document was single spaced.The result of such efforts was an illegible document on the receiving end.Accordingly, for the convenience of the parties, we request that petitioners comply with the Rules of Practice which require that all documents be double spaced.In addition, we note that petitioners imply that their.nominal reproduction costs to date ($50.00)have been substantial and apparently are onerous.In Applicant's view, such claims are inconsistent with petitioners'tatement in their first Amended Petition to Intervene (at p.7)where they stated that"HCP has fund raising (sic)abilities and abilities to finance transportation and witness fees of expert witnesses." Needless to say, all parties to a proceeding must assume the procedural and financial responsibilities of conducting the proceeding.

We trust that petitioners'equest is not.an indication that they intend to shirk these responsibilities.

Respectful submitted, DEBEVOI E LIBERNAN Nichol S eynolds Counsel o the Applicant January 19,1978 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of))WASHINGTON PUBLIC POWER)SUPPLY SYSTEM))(WPPSS Nuclear Project No.2))Docket, No.50-397-OL CERTIFICATE

'OF'SERVICE I hereby certify that copies of"Applicant's Answer To Petitioners'equest For Waiver of 10 C.F.R.52.708(b)," dated January 19, 1979, in the captioned matter have been served upon the following by deposit in the United States mail this 19th day of January, 1979: Elizabeth S.Bowers, Esq.Chairman, Atomic Safety and Licensing Board U.S;Nuclear Regulatory Commission Washington, D.C.20555 Dr.Richard F.Cole Atomic Safety and Licensing Board Panel U.S.Nuclear Regulatory Commis sion Washington, D.C.20555 Mr.Ernest, E.Hill Lawrence Livermore Laboratory University of California P.O.Box 808, L-123 Livermore, California 94550 Chairman, Atomic Safety and Licen'sing Board U.S.Nuclear Regulatory Commis sion Washington, D.C.20555 Chairman, Atomic Safety and-Licen'sing Appeal Board U.S.Nuclear Regulatory Commission Washington, D.C.20555 William D.Paton, Esq.Office of the Executive Legal Director U.S.Nuclear Regulatory Commission Washy.ngton, D.C.20555

Mr.Nicholas D.Lewis Chairman Energy Facility Site Evaluation Council 820 East.Fifth Street Olympia, Washington 98501 Thomas F.Carr, Esq.Assistant Attorney General Temple of Justice Olympia, Washington 98504 Richard Q.Quigley, Esq.Washington Public Power Supply Syst: em Post, Office Box 968 Richland, Washington 99352 Mr.Creg Darby 2425 S.E.24th Street Portland, Oregon 97214 Ms.Susan M.Garrett 632 S.E.18th Street Portland, Oregon 97214 Doreen L.Nepom, Esq., Nepom 6 Rose Suite 101-Kellogg Building 1935 S.E.Washington Milwaukie,'regon 97222 Mr..Chase R.Stephens Docketing 6 Service Section U.S.Nucleai Regulatory Commission Washington, D.C.'0555 Nichol s S.eynolds cc': 'erald C.Sorensen O.Keener Earle