ML18283A567
| ML18283A567 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/10/1976 |
| From: | Dawn Powell, Rosenberg B Tennessee Valley Authority |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML18283A567 (38) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board Xn the Matter of TENNESSEE VALLEY AUTHORITY (Browns Ferry Nuclear Plant Units 1 and 2)
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Docket Nos.
50-25 0-26 LICENSEE'S OBJECTIONS TO INTERROGATORIES OF WILLIAME.
GARNER On April 30, 1976, William E. Garner served upon the Licensee a
set of interrogatories consisting of 297 questions.
A cursory reading of those interrogatories reveals a complete disregard for the Commission's Rules of Practice in regard to discovery.
Many questions are totally unre-lated to any of the contentions in this proceeding and are contrary to the Rules of Practice limiting discovery to matters which are relevant to the subject matter involved in the"proceeding or which reasonably appear'. calcu-lated to lead to the discovery of admissible
- evidence, 10 C.F.R. 5
. 2.740(b)(1)
(1975)
~
Numerous interrogatories simply state that a copy of a document should be attached to the answer.
That'ractice is contrary to the Rules
\\
of Practice which provide the proper procedure for requesting the produc-tion and inspection of documents.
10 C.F.R. 5 2.741(a)
(1975).
Intervenor has no right to demand and shift upon the Licensee the cost of reproduction of documents.
Barrows v. Koninkli ke Luchtvaart Maatscha i, ll F.R.D.
400
P
(S.D.N.Y. 1951).
While TVA desires to cooperate in giving the Intervenor copies of relevant documents, wholesale demands for irrelevant materials serve only to frustrate the orderly progression of the proceeding.
Infor-mality in the proceeding should not extend to waiving the Rules of Practice.
Numerous interrogatories, without any showing of relevance, request the name, education, experience, and position of TVA employees.
TVA generally objects to those interrogatories on the grounds that disclosure of such infor-mation is prohibited by the Privacy Act of 1974, 5 U.S.C.
5 552a (1970; Supp.
H IV% 1974).
While it is the Licensee's desire and need to expedite these pro-
- ceedings, the setting aside of the Rules of Practice would not serve that purpose but would instead result in added delay and a chaotic record.
Without waiving its right to object to any further interrogatories, Licensee makes the following specific objections to interrogatories propounded by William E. Garner.
Interro ator 1
TVA objects to this interrogatory on the grounds that it. is overly broad and irrelevant to any issues in this proceeding.
The interrogatory is not limited to any specific type of TVA facilities nor to any specific time period.
- Thus, TVA would need to search records extending back to 1933 to fully answer this interrogatory.
This would obviously place an unreasonably great burden on TVA.
Moreover, this interrogatory appears to relate to para-graph 11 of Intervenor's Petition for Leave to Intervene and Demand for Hear-
~in (November 6, 1975), which is not a contention in this proceeding.
Interro ator 2
TVA objects to this interrogatory on the grounds as stated in ob-jection to Interrogatory 1.'oreover, this interrogatory is objectionable Zn that it calls for a legal opinion.
Cf. ~Jose h v. Norman's Health Club Inc.,
336 F. Supp.
- 307, 319 (E.D. Mo. 1971).
Federal Practice 1l 26.56[3].
Interro ator 4
TVA objects to this interrogatory on the grounds as stated in ob-
)ection to Interrogatory l.
Interro ator 5
TVA objects to this interrogatory on the grounds it requests a
legal opinion (cf. ~Jose h v. Noraan's Health Club inc.,
336 P.
Supp.
- 307, 319 (E.D. Mo. 1971);
4 O'. Moore, Federal Practice 1f 26.5613]).
Interro ator 6
TVA objects to this interrogatory on the grounds as stated in ob-jection to Interrogatory 5.
- Moreover, as an agency of the Federal govern-
- ment, TVA is entitled to the presumption that its actions are in compliance with applicable laws and regulations.
United States v. Chemical Foundation, 272 U.S. 1, 14-15 (1926); Arkansas-Best Frei ht S stem Inc. v. United States, 350 F. Supp.
539 (W.D. Ark. 1972).
See also Arkansas Power and Li ht Co.
(Arkansas Nuclear One Unit 2) ALAB-94, 6 AEC 25, 28 (Jan.
8, 1973).
Interro ator 8
Air leaks in the cable spreading room were originally filled with polyurethane
- foam, a known flammable material.
TVA objects to that part of this interrogatory requesting personal
- .information about TVA employees on the grounds that it is irrelevant, overly I
- broad, and unduly burdensome.
TVA has over 25,000 employees, and to respond to this interrogatory would require TVA management to interview each of those employees.
Furthermore, the information requested is a record within the mean-ing of the Privacy Act of 1974, 5 U.S.C.
5 552a (1970; Supp. IV, 1974). That Act defines record to include an individual's "employment history" and prohibits release of that information without the individual's express prior consent, except in certain specified cases.
Unauthorized disclosure of that informa-tion subjects the disclosing Federal employee to a
$5,000 fine and subjects TVA to damage suits by the individual concerned with a minimum $1,000 recovery.
Interro ator 16 TVA objects to this interrogatory on the grounds that it is irre-levant to any of the contentions admitted in this proceeding and, further-more, would not appear to be reasonably calculated to lead to the discovery of admissible evidence.
- Moreover, TVA objects to this interrogatory on the grounds that the information requested would require the disclosure of information pro-hibited by the Privacy Act of 1974.
See objection to Interrogatory 8.
Finally, several of the individuals named are not TVA employees; and, accordingly, the requested information is not within TVA's knowledge.
lnterro ator 17 TVA is unable to answer this interrogatory without some specific-ity and particularization of the times,.places, and subject matter of "the discussions" with James A. Elsner.
Furthermore, TVA objects to that; part of the interrogatory requesting the education and experience of individuals in that the disclosure of such information would violate provisions of the Privacy Act of 1974.
See objection to Interrogatory 8.
Interro,ator 18 t
TVA objects to this interrogatory since it's overly broad, irre-
- levant, and constitutes a request for the production of documents.
Such a request must be made in accordance with Section 2.741 of the Rules of Prac-tice.
Furthermore, the Licensee is not required to bear the expense of mak-ing copies of documents, Barrows v. Koninkli ke Luchtvaart Maatscha i,
11 F.R.D. 400 (S.D.N.Y. 1951), but is only required to make copies of requested materials available for inspection and copying, 10 C.F.R. 5 2.741(a)(l) (1975).
Interro ator 19 TVA objects to 'this interrogatory on the grounds that it is irre-
~ I levant and constitutes a request for the production of documents.
See objec-tion to Interrogatory 18.
Interro ator'.
20 (For identification, the six parts of this interrogatory are set forth below.)
[1] State in detail any increased NRC scrutiny that you have ob-served of the Bellefonte, Watts Bar, Sequoyah, Hartsville, Phipps
- Bend, Clinch River, and Yellow Creek Reactor Projects.
[2] State in detail any observation you have made of the March 22 fire being '"a major consideration" in NRC review of designs for the Bellefonte, Watts Bar, Sequoyah, Hartsville, 1
Phipps Bend, Clinch River, and Yellow Creek Reactor Projects.
[3J List in detail "construction anomalies" that did not meet design specifications that the NRC investigators found after the March 22, 1975, fire.
[4] List in de-tail "construction anomalies" that did not meet design specifications that the NRC investigators did not find after'the March 22, 1975, fire.
[5J List the name, education, experience and position, past and present, of each per-son responsible for the plant not being built according to the design that was approved by the Atomic Energy Commission.
Have any of these people been disciplined? If so, give details.
If not, why not?
[6] Explain in detail, why you did not build the plant according to the design that was approved by the AEC.
Objection:
TVA objects to parts 1 and 2 of this interrogatory on the grounds that a statement of "any increased NRC scrutiny" of the Belle-fonte, Watts Bar, Sequoyah, Hartsville, Phipps Bend, Clinch River, and
Yellow Creek Nuclear Plants and observations that the March 22 fire have been "a major consideration" in the NRC review of designs for those plants are vague, overly broad, and irrelevant to this proceeding.
- Moreover, these parts of the interrogatory request information that is neither factual nor within TVA's knowledge and, accordingly, are not proper matters for discovery.
TVA objects to parts 5 and 6 of this interrogatory on the grounds that they are vague and unduly broad.
TVA cannot respond to these questions in the absence of any specificity concerning "the design" and in the absence of any particularization of specific portions of "the design" approved by the Atomic Energy Commission.
Interro ator 21 TVA objects to this interrogatory on the grounds that it is vague,
- overly broad, and irrelevant to any issues in this proceeding.
Interro ator 25 TVA objects to this interrogatory on the grounds that it is irre-levant to any of the matters at issue in this proceeding.
Furthermore, the named individual is not a TVA employee; and, accordingly, the information requested is not within TVA's knowledge.
Interro ator 26 TVA objects to this interrogatory on the grounds that it is vague, overly broad, and constitutes a request for the production of documents.
See objection to Interrogatory 18.
Interro ator 33 TVA objects to this interrogatory on the grounds that it is an allegation or contention and requires that unproven facts be assumed as true.
- Moreover, the interrogatory is obviously vague.
Interro ator 42 TVA objects to this interrogatory on the grounds that it is irre-levant to any issues in this proceeding and is not reasonably calculated to lead to the discovery of admissible" evidence.
Interro ator 43 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 44 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 45 TVA objects to this interrogatory on the grounds that it is irre-levant to any issues in this proceeding and is not reasonably-calculated to lead to the discovery of admissible evidence.
Furthermore, u'nder the Rules of Practice this interrogatory improperly constitutes a request for the pro-duction of documents.
See objection to Interrogatory 18.
Interro ator 46 This interrogatory is objectionable on the grounds that it requests personal data, the disclosure of which is prohibited by the Privacy Act of 1974.
Additionally, under the Rules of Practice this interrogatory improperly
constitutes a request for the production of documents.
- However, no corre-spondence has been sent by TVA concerning the Browns Ferry fire to Senator Howard H. Baker, Jr.
Interro ator 47
'TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 46.
- However, no correspondence has been sent by TVA concerning the Browns Ferry fire to Representative Robert E. Jones.
Interro ator 48 TVA objects to this interrogatory on the grounds set forth in ob)ection to Interrogatory 42.
interro ator 49
, TVA ob)ects to this interrogatory on the grounds set forth in ob)ection to Interrogatory 42.
Interro ator 50 TVA objects to that part of,this interrogatory requesting the education, experience, and position of each TVA and GE employee who con-versed with William A. Anders on the grounds that the disclosure of such
~
information is prohibited by the Privacy Act of 1974.
See objection to Interrogatory 8.
Moreover, information concerning those persons who are not TVA employees is not within TVA's knowledge.
Furthermore, this inter-rogatory improperly constitutes a request for the production of documents.
4 See objection to Interrogatory 18.
Interro ator 51 TVA 'objects to this interrogatory on the grounds set forth in
~ l objection to Interrogatory 42.
TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 53 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Furthermore; the disclosure of the infor-mation requested is prohibited under the provisions of the Privacy Act of 1974 as stated in the objection to Interrogatory 8.
Interro ator 54 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 55 TVA objects to this interrogatory on the grounds that it assumes facts not shown to be true and is more in the nature of an allegation than an interrogatory.
Moreover, this interrogatory is irrelevant to any issues in this proceeding.
Interro ator 57 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 59 TVA 'objects to this interrogatory on the grounds set forth in obgection to Interrogatory 42.
Furthermore, this interrogatory seeks information not within the knowledge of TVA.
Interro ator 60 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 59.
Interro ator 62 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 64 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 66 TVA objects to this interrogatory on the grounds that is is im-pertinent, unprofessional, and obviously unrelated to the contentions in this proceeding.
Interro ator 70 TVA objects to".this interrogatory on the grounds set forth in objection to Interrogatory 42.
Moreover, this interrogatory is overly broad and vague.
Interro ator 71 TVA objects to this interrogatory on the grounds as set forth in ob)ection to Interrogatory 70.
v Interro ator 72 TVA'objects to this interrogatory on the grounds set forth in
~ I objection to Interrogatory 42.
Interro ator 73 TVA objects to ".this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 74 F
TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 75 TVA objects to this interrogatory on the grounds set forth in
,objection to Interrogatory 42.
Xnterro ator 76 TVA objects to this interrogatory 'on the grounds set forth in objection to Interrogatory 42.
Interro ator 77 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 78 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 79 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 80 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 81 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 84 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Moreover, this interrogatory is totally
'frivolous and makes a mockery of the discovery procedures.
Interro ator 86 TVA objects to that part of this interrogatory requesting the education, experience, and position of certain TVA employees on the grounds that the information requested would require the disclosure of information prohibited by the Privacy Act of 1974.
See objection to Interrogatory 8.
Interro ator 91 TVA objects to this interrogatory on the grounds set forth in obgection to Xnterrogatory 42.
14 Interro ator 92 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 93 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 94
.TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 95 TVA objects to this interrogatory on the grounds set forth in
~objection to Interr'ogatory 42.
Interro ator 96 TVA objects to thisinterrogatory on the grounds set forth in objection to Interrogatory 42.
'Interro ator 97 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Moreover, under the Rules of Practice this interrogatory improperly constitutes a request for the production of docu-ments.
See objection to Interrogatory 18.
Interro ator 98 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 99 TVA'objects to this interrogatory on the grounds set forth in objection to Interrogatory 42, Moreover, this interrogatory requests the disclosure of information prohibited by the Privacy Act of 1974, See objection to Interrogatory 8.
Interro ator 100 TVA objects to that part of the interrogatory concerned with pre-fire problems on the grounds that matters arising at that point in time are irrelevant to any issues in this proceeding.
Interro ator 101 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Moreover, this interrogatory requests the C
disclosure of information prohibited by the provisions of the Privacy Act of 1974.
See objection to Interrogatory 8.
Interro ator 102 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 103 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 104 TVA objects to this interrogatory on the grounds that it cannot respond without some further identification of "Dx. Stackles'eport."
TVA is not aware of any such report.
Xnterro ator 105 TVA objects to this interrogatory on the grounds set forth in objection to Interroga'tory 42.
Moreover, this interrogatory is unduly broad and burdensome.
This interrogatory would require Mr. Green to con-
- duct an extensive literature search and analysis of all material written concerning the fire at Browns Perry. It is obvious that such a task would be of monumental proportions and would be of zero value in resolving the issues in this proceeding.
Xnterro ator 106 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 107 TVA objects to this interrogatory on the grounds set forth in II objection to Interrogatory 42.
Interro ator 108 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 109 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 110 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
~ 4 e
Interro ator ill TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 113 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42, Moreover, under the Rules of Practice this interrogatory improperly constitutes a request for the production of docu-ments.
See objection to Interrogatory 18.
Interro ator 114 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 113.
"Interro ator 115 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro atories 118-272 TVA objects to these interrogatories on the grounds set foith in objection to Interrogatory 42.
Moreover, the great majority of these interrogatories concern events that occurred prior to March 1975.
Interro ator 273 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
I
'l
Interro ator 274 TVA 'objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 275
, TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Internal TVA personnel procedures are out-side the jurisdiction of the Nuclear Regulatory Commission.
Xnterro ator 276 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 277
- TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 278 TVA objects to this interrogatory on the grounds set forth in
,objection to Interrogatory 42.
Xnterro ator 279 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Xnterro ator 280 TVA objects to this interrogatory on the grounds set forth. in objection to Interrogatory 42.
Interro ator 281 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 282 TVA objects to this interrogatory on the 'grounds set forth in objection to Interrogatory 42.
Interro ator 283 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 284 TVA objects to this interrogatory on the grounds set forth in
- objection, to Interrogatory 42.
Moreover, the information requested would require the disclosure of information prohibited by the Privacy Act of 1974.
See objection to Interrogatory 8.
Interro ator 285 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 286 TVA objects to this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 291 Question:
(For identification purposes, this interrogatory has been divided into numbered parts as indicated below.)
Explain why it was necessary and what work was done on the fol-lowing items from part XIV, Section A, Recover Plan, BFNP, Revised 1/26/76:
(p stands for page and. i stands for item):
Unit 0:
[1] p. 3, i. 0-35; [2] p. 11, i. 27-3, 27-4, 27-5; [3] p. 12, 27-7; [4] p. 13, i. 28-6;
[5] p. 17, i. 39-1;
[6J p. 20, i. 57-1, 57-6
[7] p. 25, i. 77-1; [8] p. 45, i. 426-1.
Unit I Modification:
[9] p. 3, i. 0-18;
[10] p. 15, i. 6-1; [11] p. 22, 27-4;
[12] p. 48, i, 67-2;
[13] p. 50, i. 68-2;
[14J p. 100, i. 327-1;
[15] p. 101, i. 400-1; L16J p. 103, i. 401-1;
[17J p.
104~ i. 404-2>>
L18J
- p. 106, i. 433-1.
Unit II:
[19] p. 4, i. 23; [20] p. 8, i. 47;
[21J p. 9, i. 53; [22] p. 10, 55;
[23J p. 15, i. 122;
[24J p. 30, i. 304.
Unit II Modifications:
[25J p. 1, i. 0-6; [26] p. 42, i. 66-16;
[27]
- p. 64, i. 82-6, i. 82-8; [28] p. 68, i. 85-44;
[29J p. 85, i. 258-1;
[30]
- p. 93, i.
400-3.'bjection:
,TVA objects to parts 2, 3, 4, and 6 through 30 of this interrogatory on the grounds set forth in objection to Interrogatory 42.
Interro ator 292 TVA objects to the second part of this interrogatory requesting explanations of various work items from the Recovery Plan for BFNP on the grounds set forth in objection to Interrogatory 42.
Interro ator 295 Question:
(For identification purposes, this interrogatory has been divided into numbered parts as indicated below.)
Give details of the work performed and documentation of quality assurance and audit, including the names, education, experience, qualifi-
~ F cations and title, of the persons responsible for doing the work, the quality assurance and audit for the following items from Part XIV> Sec-tion A, Recovery Plan, BFNP, Revised 1/26/76.
For incomplted [sic] work give information on work to date:
Unit 0:
fl] p. 1, i. 0-12.
Unit I:
[2] p. 5, i. 25;
[3J p. 9,'. 51;
[4J p. 17, i. A 5; [5] p. 20, 116; [6] p.
21, i. 121; [7] p. 24, i. 139; [8] p. 37, i. 241; [9]
- p. 45, i. 324;
[10] p. 87. i. 605; [11] p. 88, i. 606; [12] p. 90, i. 617;
[13] p.
91, i. 620;
[14] p. 95, i. 643;
[15] p. 96, i. 648;
[16] p. 97, 656 and i. 657;;
[17] p. 98. i. 658.
'Unit,I - Modifications:
[18] p. 42, i. 64-22;
[19J p.
61, i. 74-22;
[20]
- p. 101, 400 11.
Unit II:
[21] p. 3, i. 13,;
[22] p. 4, i. 20; [23] p. 7, i. 40;
[24J p. 25, 222
& 223;
[25J p. 35, i. 417;
[26J p. 53, i. 618;
[27J p. 53, i. 619;
[28J p. 55, i. 630.
Unit II Modifications:
[29J p. 1, i.0-17;
[30J p. 39, i. 66-25.
Objection:
TVA objects to the following parts of this interroga-tory on the grounds that they are irrelevant to any issues in this proceed-ing and are not reasonably calculated to lead to the discovery of admissible evidence:
2 through 5, 7, 9, 18, 19, 21, 22, 25, and 30.
Interro ator 293 TVA 'objects to this interrogatory on the grounds of undue burden and irrelevancy.
The "Remarks" column of Part XIV, Section A, Recovery Plan consists of several hundred pages and lists hundreds of individual work items.
It is obvious.that the collection and reporting of the cur-rent status of such a voluminous amount of information would require an extensive effort.
Furthermore, the great majority of those work items listed are totally foreign to the fire-related modifications at the plant
- and, thus, irrelevant to the proceeding.
The information contained in the "Remarks" column is essentially a tool for the use of TVA management to keep track of ongoing work at the Browns Ferry Plant.
Therefore, TVA does plan to issue an updated revision of this section in several months after fuel loading activities have been completed.
That update will then be made available to the Intervenor.
Respectfully submitted,
,.;.I k4.(
Davi G. Powell Assistant General Counsel Tennessee Valley Authority Knoxville, Tennessee A c ruce M. Rosenberg Attorneys for Licensee Knoxville, Tennessee May 10, 1976
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of TENNESSEE VALLEY AUTHORITY (Browns Ferry Nuclear Plant Units 1 and 2)
)
)
)
),)
)
Docket Nos.
50-259 50-260 CERTIFICATE OF SERVICE I hereby certify that
~I have served the original and 20 conformed copies of the following document on the Nuclear Regulatory Commission by depositing them in the United States mail, postage prepaid and addressed to Secretary, U.S. Nuclear Regulatory Commission, Washington, D.C.
- 20555, Attention:
Chief, Docketing and Service Section:
Licensee's Objections to Interrogatories of William E.Garner
'and that I have served a copy of the above document upon the persons listed below by depositing it in the United States mail, postage prepaid and addressed:
Thomas W. Reilly, Esq.,
Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Frederick P.
Cowan 22 Browns Lane Bellport, New York 11713
Dr. Hugh C. Paxton Los Alamos Scientific Laboratory P.O.
Box 1663 Los Alamos, New Mexico '87544 James R. Tourtellotte, Esq.
Lawrence E. Brenner, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 William E. Garner, Esq.
Route 4, Box 354 Scottsboro, Alabama 35768 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission
, Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 This 10th day of May, 1976.
Bruce M. Rosenberg Attorney for Licensee Tennessee Valley Authority