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| issue date = 01/19/1979
| issue date = 01/19/1979
| title = Applicant Answer in Opposition to Petitioners Darby Garrett & Hanford Conversion Project Request for Waiver of 10CFR2.708(b).W/encl Certificate of Svc
| title = Applicant Answer in Opposition to Petitioners Darby Garrett & Hanford Conversion Project Request for Waiver of 10CFR2.708(b).W/encl Certificate of Svc
| author name = REYNOLDS N S
| author name = Reynolds N
| author affiliation = DEBEVOISE & LIBERMAN
| author affiliation = DEBEVOISE & LIBERMAN
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter: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.
{{#Wiki_filter:UNITED STATES OF, AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
'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.
                                  '7'f)
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.
WASHINGTON PUBLIC POWER               )
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
SUPPLY SYSTEM                     ) Docket No. 50-397-OL
'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
                                      )
(WPPSS   Nuclear Project No. 2)       )
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,


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}}
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                )  Docket, No. 50-397-OL
                                )
(WPPSS Nuclear Project No. 2)  )
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 Chairman, Atomic Safety and              Licen'sing Board Licensing Board                    U.S. Nuclear Regulatory U.S; Nuclear Regulatory                  Commis sion Commission                        Washington, D.C. 20555 Washington, D.C. 20555 Chairman, Atomic Safety and Dr. Richard F. Cole                    -Licen'sing Appeal Board Atomic Safety and Licensing          U.S. Nuclear Regulatory Board Panel                          Commission U.S. Nuclear Regulatory              Washington, D.C. 20555 Commis sion Washington, D.C. 20555              William D. Paton, Esq.
Office of the Executive Mr. Ernest, E. Hill                      Legal Director Lawrence Livermore Laboratory        U.S. Nuclear Regulatory University of California                Commission P.O. Box 808, L-123                  Washy.ngton, D.C. 20555 Livermore, California 94550
 
Mr. Nicholas D. Lewis          Ms. Susan M. Garrett Chairman                        632 S.E. 18th Street Energy Facility Site            Portland, Oregon 97214 Evaluation Council 820 East. Fifth Street        Doreen L. Nepom, Esq.,
Olympia, Washington      98501  Nepom 6 Rose Suite 101 Kellogg Building Thomas F. Carr, Esq.        1935 S.E. Washington Assistant Attorney General      Milwaukie,'regon 97222 Temple    of Justice Olympia, Washington      98504  Mr..Chase R. Stephens Docketing 6 Service Section Richard Q. Quigley, Esq.        U.S. Nucleai Regulatory Washington Public Power          Commission Supply Syst: em              Washington, D.C.'0555 Post,  Office  Box 968 Richland, Washington      99352 Mr. Creg Darby 2425 S.E. 24th Street Portland, Oregon      97214 Nichol s S. eynolds cc': 'erald   C. Sorensen O. Keener Earle}}

Latest revision as of 16:53, 29 October 2019

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 Energy Northwest icon.png
Issue date: 01/19/1979
From: Reynolds N
DEBEVOISE & LIBERMAN
To:
References
NUDOCS 7901300024
Download: ML17272A269 (5)
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Text

UNITED STATES OF, AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

'7'f)

)

WASHINGTON PUBLIC POWER )

SUPPLY SYSTEM ) Docket No. 50-397-OL

)

(WPPSS Nuclear Project No. 2) )

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 ) Docket, No. 50-397-OL

)

(WPPSS Nuclear Project No. 2) )

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 Chairman, Atomic Safety and Licen'sing Board Licensing Board U.S. Nuclear Regulatory U.S; Nuclear Regulatory Commis sion Commission Washington, D.C. 20555 Washington, D.C. 20555 Chairman, Atomic Safety and Dr. Richard F. Cole -Licen'sing Appeal Board Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commis sion Washington, D.C. 20555 William D. Paton, Esq.

Office of the Executive Mr. Ernest, E. Hill Legal Director Lawrence Livermore Laboratory U.S. Nuclear Regulatory University of California Commission P.O. Box 808, L-123 Washy.ngton, D.C. 20555 Livermore, California 94550

Mr. Nicholas D. Lewis Ms. Susan M. Garrett Chairman 632 S.E. 18th Street Energy Facility Site Portland, Oregon 97214 Evaluation Council 820 East. Fifth Street Doreen L. Nepom, Esq.,

Olympia, Washington 98501 Nepom 6 Rose Suite 101 Kellogg Building Thomas F. Carr, Esq. 1935 S.E. Washington Assistant Attorney General Milwaukie,'regon 97222 Temple of Justice Olympia, Washington 98504 Mr..Chase R. Stephens Docketing 6 Service Section Richard Q. Quigley, Esq. U.S. Nucleai Regulatory Washington Public Power Commission Supply Syst: em Washington, D.C.'0555 Post, Office Box 968 Richland, Washington 99352 Mr. Creg Darby 2425 S.E. 24th Street Portland, Oregon 97214 Nichol s S. eynolds cc': 'erald C. Sorensen O. Keener Earle

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