ML18025A680

Motion for Extension of Time to Answer or Object to First Round Interrogatories of Applicant and NRC by Intervenor Sea

ML18025A680
Person / Time
Site:	Susquehanna
Issue date:	09/12/1979
From:	Jay Robinson, Schultz G Susquehanna Environmental Advocates
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18025A680 (3)

Text

September 12, 1979 UiiXTED STATES OF AMERICA NU~~<REGULATORY CQ~IMISS ION BEFORE THE ATCiMC SAFETY AND LI~SWG BOARD In the Hatter of: Pennsylvania Power and Light.COHpany I Allegheny Electric Cooperative (Susquehanna Steam Electric Station Units 1&2)))))KXXZET NOS.:))50-387))50-388))u~6 M7ZICN FOR EZIMSION OF TLK TO PiVSKR OR OB3ZCT TO FIRST ROUND INTERROGATORIES OF APPLIC'AVZ AND NRC BY INTERVENOR SEA Intervenor SEA ccmes now and@aves for an extension of tim to answer or object to the first round interrogatories of the applicant and the NRC for the following reasons which constitute, equal and anent to good cause, pursuant to 10 CFR 2.711(a): 1)Fourteen (14)days is simply not enough time to prepare answers or objections to such lengthy, burdensome, oppressive interrcgatories.

The applicant, staff, and the Board knew M.l well that it would take a full time staff, including an attorney, radiation physicist and engineer, at least six (6)months to adequately answer or object to these c;aasonian interro-gatories.The applicant, staff and Board also know that SEA is a volunteer citizens organization without tl necessary full time staff and resources.

To allow SEA only 14 days to respond after denial of our motion for a protective order is punitive and offensive to any recruits of proca2ural due prccess and fairness that the Board might retain.If the Board dces not grant, a reasonable extension of time, pursuant to 10 C.F.R.2.711(a), for SEA to respond, it vill only danonst ate that&~BOARD, while giving lip se~ce to effective citizen participation, merely desires to rush through the hearings and grant an operating license.2)SEA, and, to its kna~ledge, the other intervenors,=have not had, access to a copy of the prehearing conference transcript outside Ma local public decurrent rocm, in direct contravention of the Board's own Special Pre-hearing Conference Order (i~~>>ch 6, 1979).The Staff has not lent one of its copies to the interverzors.

The Staff make no ar angements for the use of the transcript outside th LPDR as r~~'red on pace 83 of the Order.Even these pallid, condescending measures, far short of what the NRC, and the Board, should do, were not taken.This has further irrpeded SPA's ability to respond to the interrogatories.

NHEREPORE, SEA moves that the Board extend the tina limit to answer or object to the first round interrcgatories to the applicant and the NRC 180 days.SUSQUEHANNA ENVIRCÃMENTAL ADVOCREH GERAZD R.S~TZ JCHN J.ROBINSON I hereby certify that a copy of the foregoing Yotion has been served on all parties to this action.GERALD R.SCHULTZ 4