ML19321A494: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
(One intermediate revision by the same user not shown) | |||
Line 17: | Line 17: | ||
=Text= | =Text= | ||
{{#Wiki_filter:~ | {{#Wiki_filter:~ | ||
Lic 7/17/80 | Lic 7/17/80 uY6fiW@ | ||
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) g,- | |||
uY6fiW@ | |||
UNITED STATES OF AMERICA | |||
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD | |||
In the Matter of ) g,- | |||
) *} N METROPOLITAN EDISON COMPANY ) Docket No. 50-289 | ) *} N METROPOLITAN EDISON COMPANY ) Docket No. 50-289 | ||
) (Restart) // 'OOCKEHD D (Three Mile Island Nuclear ) s USNRO - | ) (Restart) // 'OOCKEHD D (Three Mile Island Nuclear ) s USNRO - | ||
Line 33: | Line 27: | ||
Office of ' | Office of ' | ||
LICENSEE'S OBJECTIONS TO ro B nch O' TMIA'S " FOLLOW-UP" INTERROGATORIES BASED ON THE JUNE 27 10,000 GALLON LEAK 4> | LICENSEE'S OBJECTIONS TO ro B nch O' TMIA'S " FOLLOW-UP" INTERROGATORIES BASED ON THE JUNE 27 10,000 GALLON LEAK 4> | ||
g 65 | g 65 On July 7, 1980 Three Mile Island Alert ("TMIA") filed a document entitled "TMIA's Follow-Up Interrogatories Based On The 10,000 Gallon Leak of Contaminated Water On June 27, 1980 To 1 | ||
On July 7, 1980 Three Mile Island Alert ("TMIA") filed a document entitled "TMIA's Follow-Up Interrogatories Based On | |||
The 10,000 Gallon Leak of Contaminated Water On June 27, 1980 To 1 | |||
Licensee."' Licensee objects to the interrogatories. | Licensee."' Licensee objects to the interrogatories. | ||
Though TMIA denominates the interrogatories as " follow-up" interrogatories, the interrogatories do not comply with the controlling Board order on follow-on discovery. The interrogatories are not " clearly tied (by express reference) to . . . [a prior given] response" of Licensee to discovery. See " Fourth Special Prehearing Conference Order," (slip op. at 23-24) (February 29, 1980). | Though TMIA denominates the interrogatories as " follow-up" interrogatories, the interrogatories do not comply with the controlling Board order on follow-on discovery. The interrogatories are not " clearly tied (by express reference) to . . . [a prior given] response" of Licensee to discovery. See " Fourth Special Prehearing Conference Order," (slip op. at 23-24) (February 29, 1980). | ||
Absent TMIA's identification of such prior response by Licensee, Licensee is unable to assess either the timeliness or relevance of TMIA's July 7 " follow-on" interrogatories. | Absent TMIA's identification of such prior response by Licensee, Licensee is unable to assess either the timeliness or relevance of TMIA's July 7 " follow-on" interrogatories. | ||
4007230 E | 4007230 E | ||
.= w : - = - | .= w : - = - | ||
= = u | = = u | ||
i The Board's May 5, 1980 " Memorandum and Order," which TMIA cites as authority for the promulgation of its July 7 interrogatories, does not even address the subject of follow-on | i The Board's May 5, 1980 " Memorandum and Order," which TMIA cites as authority for the promulgation of its July 7 interrogatories, does not even address the subject of follow-on | ||
] interrogatories. Rather, the May 5 " Memorandum and Order" establishes a schedule for the filing of discovery requests and new contentions based upon "new information." Assuming that TMIA intended to treat the June 27 leak as "new information," | ] interrogatories. Rather, the May 5 " Memorandum and Order" establishes a schedule for the filing of discovery requests and new contentions based upon "new information." Assuming that TMIA intended to treat the June 27 leak as "new information," | ||
Licensee still objects to the July 7 interrogatories as irrelevant and overly broad. TMIA does not explain how the requested information relates to TMIA's remaining contentions or how it could be said to be reasonably calculated to lead to relevant information. | Licensee still objects to the July 7 interrogatories as irrelevant and overly broad. TMIA does not explain how the requested information relates to TMIA's remaining contentions or how it could be said to be reasonably calculated to lead to relevant information. | ||
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: - | |||
Respectfully submitted, | |||
SHAW, PITTMAN, POTTS & TROWBRIDGE By: - | |||
Ernest L. Blake~, Jr. | Ernest L. Blake~, Jr. | ||
Dated: July 17, 1980 6 | Dated: July 17, 1980 6 | ||
l l | l l | ||
c - | c - | ||
t ._ a. .= .= .= - - | t ._ a. .= .= .= - - | ||
.: - - - ~. ..- | .: - - - ~. ..- | ||
Ol- Ul.p - | Ol- Ul.p - | ||
: y 1980 s - | : y 1980 s - | ||
Line 82: | Line 58: | ||
(Three Mile Island Nuclear ) | (Three Mile Island Nuclear ) | ||
Station, Unit No. 1) ) | Station, Unit No. 1) ) | ||
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Objections To | CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Objections To TMIA's ' Follow-Up' Interrogatories Based On The June 27 10,000 Gallon Leahc" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 17th day of July, 1980. | ||
TMIA's ' Follow-Up' Interrogatories Based On The June 27 10,000 Gallon Leahc" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 17th day of July, 1980. | |||
fkY Ernest L. Blake, 'Jr. | fkY Ernest L. Blake, 'Jr. | ||
Dated: July 17, 1980 i | Dated: July 17, 1980 i | ||
* $ * | * $ * | ||
* e * * * * ** .___j | * e * * * * ** .___j o | ||
o | |||
~ | ~ | ||
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD | . UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) | ||
In the Matter of ) | |||
) | ) | ||
METROPOLITAN EDISON COMPANY ) Docket No. 50-289 | METROPOLITAN EDISON COMPANY ) Docket No. 50-289 | ||
Line 110: | Line 73: | ||
SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm'& | SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm'& | ||
Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington,~D.C. 20555 Karin W. Carter, Esquire Dr.' Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Bohrd Panel Dauphin County' Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Efquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (21) | Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington,~D.C. 20555 Karin W. Carter, Esquire Dr.' Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Bohrd Panel Dauphin County' Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Efquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (21) | ||
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 | Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 I | ||
I | |||
, . . _ . , ., . , ~. . _ | , . . _ . , ., . , ~. . _ | ||
~ | ~ | ||
Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against NucleQ T.M.I. Steering Committee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Esquire - | |||
Robert Q. Pollard Widoff Reager Selkowitz & Adler Post Office Box 1547' 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nucleas ' | |||
Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire | |||
Attorney for Newberry Township Attorney for People Against NucleQ | |||
T.M.I. Steering Committee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Esquire - | |||
Robert Q. Pollard | |||
Widoff Reager Selkowitz & Adler Post Office Box 1547' 609 Montpelier Street | |||
Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nucleas ' | |||
Sneldon, Harmon & Weiss Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue | Sneldon, Harmon & Weiss Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue | ||
. Washington, D.C. 20006 State College, Pennsylvania 16801' | . Washington, D.C. 20006 State College, Pennsylvania 16801' Steven C. Sholly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149' Gail Bradford Marjorie M. Aamodt Holly S. Keck R. D. 5 Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 t | ||
Steven C. Sholly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149' Gail Bradford Marjorie M. Aamodt | |||
Holly S. Keck R. D. 5 | |||
Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 | |||
t | |||
r. | r. | ||
I l . | I l . | ||
.- <s - | .- <s - |
Latest revision as of 21:44, 18 February 2020
ML19321A494 | |
Person / Time | |
---|---|
Site: | Three Mile Island |
Issue date: | 07/17/1980 |
From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
To: | Atomic Safety and Licensing Board Panel |
References | |
NUDOCS 8007230521 | |
Download: ML19321A494 (5) | |
Text
~
Lic 7/17/80 uY6fiW@
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) g,-
) *} N METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart) // 'OOCKEHD D (Three Mile Island Nuclear ) s USNRO -
l Station, Unit No. 1) )
05
~
JUL211980 > 3)
Office of '
LICENSEE'S OBJECTIONS TO ro B nch O' TMIA'S " FOLLOW-UP" INTERROGATORIES BASED ON THE JUNE 27 10,000 GALLON LEAK 4>
g 65 On July 7, 1980 Three Mile Island Alert ("TMIA") filed a document entitled "TMIA's Follow-Up Interrogatories Based On The 10,000 Gallon Leak of Contaminated Water On June 27, 1980 To 1
Licensee."' Licensee objects to the interrogatories.
Though TMIA denominates the interrogatories as " follow-up" interrogatories, the interrogatories do not comply with the controlling Board order on follow-on discovery. The interrogatories are not " clearly tied (by express reference) to . . . [a prior given] response" of Licensee to discovery. See " Fourth Special Prehearing Conference Order," (slip op. at 23-24) (February 29, 1980).
Absent TMIA's identification of such prior response by Licensee, Licensee is unable to assess either the timeliness or relevance of TMIA's July 7 " follow-on" interrogatories.
4007230 E
.= w : - = -
= = u
i The Board's May 5, 1980 " Memorandum and Order," which TMIA cites as authority for the promulgation of its July 7 interrogatories, does not even address the subject of follow-on
] interrogatories. Rather, the May 5 " Memorandum and Order" establishes a schedule for the filing of discovery requests and new contentions based upon "new information." Assuming that TMIA intended to treat the June 27 leak as "new information,"
Licensee still objects to the July 7 interrogatories as irrelevant and overly broad. TMIA does not explain how the requested information relates to TMIA's remaining contentions or how it could be said to be reasonably calculated to lead to relevant information.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: -
Ernest L. Blake~, Jr.
Dated: July 17, 1980 6
l l
c -
t ._ a. .= .= .= - -
.: - - - ~. ..-
Ol- Ul.p -
- y 1980 s -
UNITED STATES OF AMERICA k 6 NUCLEAR REGULATORY COMMISSION %
N 0
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,
In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) -
(Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Objections To TMIA's ' Follow-Up' Interrogatories Based On The June 27 10,000 Gallon Leahc" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 17th day of July, 1980.
fkY Ernest L. Blake, 'Jr.
Dated: July 17, 1980 i
- $ *
- e * * * * ** .___j o
~
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm'&
Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington,~D.C. 20555 Karin W. Carter, Esquire Dr.' Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Bohrd Panel Dauphin County' Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Efquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (21)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 I
, . . _ . , ., . , ~. . _
~
Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against NucleQ T.M.I. Steering Committee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Esquire -
Robert Q. Pollard Widoff Reager Selkowitz & Adler Post Office Box 1547' 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nucleas '
Sneldon, Harmon & Weiss Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue
. Washington, D.C. 20006 State College, Pennsylvania 16801' Steven C. Sholly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149' Gail Bradford Marjorie M. Aamodt Holly S. Keck R. D. 5 Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 t
r.
I l .
.- <s -
_;. ~
y . .
, , , _