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 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