ML19029A511
| ML19029A511 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/08/1978 |
| From: | Wetterhahn M Conner, Moore & Corber, Public Service Electric & Gas Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML19029A511 (15) | |
Text
RELA'tE;D G0MESP0.~1DENc~. e UNITED STATES OF AMERICA
.NUCLEAR REGULATORY COMMISSION In the Matter of PUBLIC SERVICE ELECTRIC &
GAS COMPANY (Salem Nuclear Generating Station, Unit No. 1)
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Docket No.
Proposed Issuance of *Amendment to Faci*lity Operating License No." DPR~7o LICENSEE'S INTERROGATORIES. TO MR. AND MRS. ALFRED C. COLEMAN, JR.
(SET NO. 2).
Pursuant to 10 CFR §2.740b of the Nuclear* Regulatory Commission's Rules of Practice, Licensee, Public Service Electric & Gas Company, by its attorneys, hereby pro-pounds the following interrogatories to intervenor, Mr.
and Mrs. Alfred C. Coleman, Jr., to be answered fully in writing, under oath, within fourteen (14) days after service hereof in accordance with the following definitions and instructions:
Definitions and Instructions All definitions and instructions are the same as contained in "Licensee's Interrogatories to Mr. and Mrs.
alfred C. Coleman, Jr., (Set No. 1) dated June 28, 1978, with the exception that Interrogatories 1-6 relate to Contention 13, as admitted by the Atomic Safety and Licensing Board's Memorandum and Order dated July 18, 1978.
INTERROGATORIES
- l. Is the contention based on one or more calcula-ti'ons?
If-so:
(a)* Describe each calculation and identify any
_;-documents setting forth such calculation;.*
(b) Who performed each calculation?
{c) When was each calculation performed?
(d) Describe each parameter used in such calculation and each value assigned to the parameter, and describe the source of your data.
(e) What are the results of each calculation?
(f) Explain in detail how each calculation provides a basis for the issue *.
- 2.
Is the. contention based upon any type of study or analysis?* If so:
(a) Describe the nature of the study or analysis and identify any documents which disc.uss or describe the study or analysis.
(b) Who performed the study or analysis?
(c) When.and where was the study. or analysis performed?
(d) Describe in detail the information that was studied or analyzed.
(eJ What were the results of such study or analysis?
(f) Explain how such study or analysis provides a basis for the contention.
- 3.
Is the contention based upon one or more documents?
If so:
{a) Identify each such document.
(b) Identify the information in each document on
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e which the contention is based.
(c) Explain*** how -such information provides a basis for
_rthe contention.
4~ Is the contention based upon research? If so:
(a) Describe all such research and identify each document.
(b) When and where was the research conducted?
(c) By whom was the research conducted?
(d) Explain how such research provides a basis for the contention.
- 5.
Is ~he _contention based upon conversations, con-sultations, correspondence, or any other type of conununica-tions with one or more individuals? If so:
(a) Identify by name and address each such individual.
(b) State the educational and professional background of each such individual, includi~g occupation and institution-al affiliations.
(c) Desc"ribe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.
- (d) Describe the information received from such indi-viduals and explain how it provides a basis for the issue.
- 6.
Please identify each and every person whom you expect to call as an_ expert witness at the hearing in this matter on Contention 13 as admitted by the Atomic Safety & Licensing Board's Memorandum and Order dated July 18, 1978, and, with respect to each person, please:
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(a) State the contention or portion thereof on which he will testify; (b) state the substance of facts:and opinions to which the witness is expected to testify; (c) give a summary of the grounds for each fact and ~pinion; and.
(d) describe fully the witness' educational and professional bac~ground.
If no expert witnesses have been identified or you do not expect to call any expert witnesses, so indicate.
A~gust 8, J.978 Respectfully submitted, CONNER, MOORE & CORBER Mr-~
Mar~~:cJ:t~erhahn Counsel for _the Licensee
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Gw""UlliSPO.NDENCE e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of PUBLIC SERVICE ELECTRIC &
GAS COMPANY (Salem Nuclear Generating Station, Unit No. 1).
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Docket No.
Proposed Issuance of Amendment to Facility Operating License No.
DPR~7o LICENSEE'S INTERROGATORIES TO LOWER ALLOWAYS CREEK TOWNSHIP (SET NO. 1)
Pursuant to 10 CFR §2.740b of the Nuclear Regulatory Commission's Rules of Practice,.Licensee, Public Service Electric & Gas Company, by its attorneys, hereby pro-pounds the following interrogatories to intervenor, Lower Alloways Creek Township ("LACT"), to be answered fully in writing, under oath, within fourteen (14) days after service hereof in accordance with the following definitions and instructions:
- Definitions and Instructions
- 1.
~or each interrogatory, please state the full*
name, address, occupation, and employer of each person answering the interrogatory and designate the interrogatory, or part thereof, he or she answered.
- 2.
The following definitions shall apply:
(a)
"Intervenor" shall mean LACT.
(b)
"Person" shall mean an i~dividual, person, corporation, proprietorship, partnership,
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or any other entity.
(c)
"Identification" or "identity, 11 1when re-ferring to an individual, *corporation, or other entity, shall mean that the intervenor shall set forth the name, :present or last known address, and if a corporation or other entity, its principal place of business or
- if an individual his or her title or titles and by whom employed.
Once an individual, corporation, or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereafter when identi-fying that individual, corporation or other entity to state merely his, her or its name.
(d)
"Description" or "describe" when referring to a document as hereinafter defined, shall mean that intervenor shall set forth the author or originator, addressee(s), date, title and sub-ject matter, the present custodian of the original thereof and, if known, the present custodian of any copy thereof and the last known address of each such custodian.
In lieu of describing the document, intervenor may attach a copy thereof to its answers, indicati~g the question to which the attached document is intended to be responsive.
If the information requested in this paragraph does not
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appear on the face of such attached document, then intervenor shall indicate that information for each document so attached~
(e)
"Document" shall mean any written, printed, typed or any other graphic matter of.any kind or nature, and all mechanical p.nd electronic sound recordings or transcripts thereof, in the possession, custody, or control of inter-venor, or its officials, employees, or agents;*
it shall also mean all copies of documents by whatsoever means made.
(f)
"Date" shall mean exact day, month and year if ascertainable, or, if not ascertainable, the best approximation (including relationship
- to other events).
- 3.
These interrogatories request all knowledge or information in intervenor's possession and/or knowledge and information in the possession of intervenor's agents, representatives, and, unless privileged, attorneys.
- 4.
These in.terrogatori~s apply to LACT Contentions 1 and 3 admitted as issues in controversy in this proceeding by the Atomic Safety and Licensing Board's Memorandum and Order dated April 26, *1978.
In your response to the follow-ing interrogatories, pl~ase supply the re_quested information, indicate which contention is being addressed and to which of the interrogatories or its subparts the response is being made.
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INTERROGATORIES
- 1.
Is the contention based on one or more calcula-r*
- tions?
If so:
(a)
Describe each calculation and identify any documents setting forth such calculation.
(b)
Who performed each calculation?
(c)
When was each calculation performed?
(d)
Describe each parameter used in such calcu-lation and each value assigned to the para-meter, and describe the source of your data.
(e)
What are the results of each calculation?
(f)
Explain in detail how each calculation provides a basis for the issue.
- 2.
Is the contention based upon any type of study or analysis? If so:
(a)
Describe the nature of the study or analysis and identify any documents which discuss or describe the study or analysis.
(b}
Who performed the study or analysis?
(c)
When and where was the study or analysis performed?
(d}
Describe in detail the information that was studied or analyzed.
(e)
What were the results of. such study or analysis?
(f}
Explain how such study or analysis provides a basis for the contention.
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- 3.
Is the contention based upon one or more documents?
If so:
(a)
Identify each such document.
(b)
Identify the information in each document on which the contention is based.
{c)
Explain how such information provides a basis for the contention.
- 4.
Is the contention based upon research? If so:
{a)
Describe all such research and identify each document.
{b)
When and where was the research conducted?
(c)
By whom was the research conducted?
(d)
Explain how such research provides a basis for the contention.
- 5.
Is the contention based upon conversations, con~
sultations, correspondence, or any other type of communica-tions with.one or more individuals? If.so:
(a)
Identify by name and address each such individual.
{b)
State the educational and pr_ofessional background of each such individual, including occupation and institutional affiliations.
(c)
Describe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.
(d)
Describe the information received from such individuals and explain how it provides a basis for the issue.
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- 6.
Please identify each and every person whom you expect*. to call as an expert witness at the hearing in this matter on each contention granted to*LAcT by* the Atomic Safety & Licensing Board, and, with respect to each person, please:
(a)
State the contention or portion thereof on which he will testify; (b) state the substance of facts and opinions to which the witness is expe.cted to testify; (c) give a sununary 0£ the grounds for each fact and opinion; and (d}
describe fully the wi tness.1 educational and professional background.
If no expert witnesses have been iden.tif ied or you do not expect to call any expert witnesses, so indicate.
August 8, 1978 Respectfully submitted, CONNER, MOORE & CORBER Mark J. Wetterhahn Counsel for the Licensee
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of
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PUBLIC SERVICE ELECTRIC &
GAS COMPANY Docket No. 50-272 Proposed Issuanc~
of Amendment to Facility Operating License No. DPR-70 (Salem Nuclear Generating Station, Unit No. 1)
LICENSEE'S REQUEST FOR ADMISSIONS FROM MR. AND MRS. COLEMAN (SET NO. 2)
Pursuant to 10 CFR §2.742 of the Nuclear Regula-tory Commission's Rules of Practice, the Licensee in the captioned proceeding, Public Service Electric & Gas Company, by its attorneys, hereby propounds the follow-
.ing.request for admissions to intervenors, Mr. and Mrs.
Alfred C. Coleman, Jr.
Each requested admission will be deemed made, unless intervenor, in writing, under oath and within ten days, specifically denies the state-*
ments or explains in detail why he cannot truthfully admit or deny them, or objects pursuant to that section.
Licensee requests that intervenor, Mr. Alfred C.
Coleman, Jr., admit the truth of. the following:
- 1.
Intervenor, Mr. Alfred c. Coleman, Jr., has no scientific or technical training, experience and/or other expertise with rega~d to any matters raised in Contention 13 which was granted by the Memorandum and Order dated July 18, 1978.
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- 2.
Intervenor, Mr. Alfred C. Coleman, Jr., does not hold himself. *out* as an expert.with regard to any matters
_,-raised in Contention 13 which was.granted by the Memorandum arid Order dated July 18,.1978.
- 3.
Intervenor, Mr. Alf red c. Coleman, Jr. I will not seek to become an expert witness with regard to any matters raised in Contention 13 which was granted by the Memorandum and Order dated July 18, 1978.
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- 4.
Intervenor, Mr. Alfred c. Coleman, Jr., is not a qualified individual who has scientific or technical training or experience for the purpose of examining or crossexamining expert witnesses pursuant to 10 CFR §2.733 with regard to any matters raised in Contention 13 which was granted by the Memorandum and Order dated July 18, 1978.
Licensee requests that intervenor, Mrs. Alfred c.
- Coleman, Jr., admit the truth of the following:
- l. Intervenor, Mrs. Alfred c. Coleman, Jr., has no scientific or technical training, experience and/or other expertise with regard to any matters raised in Contention 13 which was granted by the Memorandum and Order dated July 18, 1978.
- 2.
Intervenor, Mrs. Alfred C. Coleman, Jr., does not hold herself out as an expert with regard to any matters raised in Contention 13 which was granted by the Memorandum and Order dated July 18, 1978.
- 3.
Intervenor, Mrs. Alfred c. Coleman, Jr., will not seek to become an expert witness with regard to.any matters raised in Contention 13 which was. granted by the Memorandum and Order dated July 18, 1978.
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- 4.
Intervenor, Mrs. Alfred C *. Coleman, Jr., is not a qualified individual who has scientific or technical training or experience for the purpose of examining or crossexamining expert witnesses pursuant to 10 CFR §2.733 with regard to any matters raised in Contention 13. g~anted by the Memorandum and Order dated July 18, 1978.
Respectfully submitted, CONNER, MOORE & CORBER
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Counsel for Licensee.
A~gust 8, 1978
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UNITED STATES OF AMERIClJ...
9:icLEAR REGULATORY COMMIS.N -a~f~ ~r.~M>ENCB Before the Atomic Safety and Licensing Board In the Matter of PUBLIC SERVICE ELECTRIC AND GAS COMPANY, et* al.
(Salem Nuclear Generating Station, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify t~at copies of:
(1)
"Licensee's Request for Admissions from Mr. and Mrs.
Coleman (Set No. 2):," dated August 8, 1978, (2)
"Licensee's Interrogatories to Mr. and Mrs. Alfred C.
Coleman,.Jr. (Set No. 2)," dated August 8, 1978, and (3)
"Licensee's Interrogatories to Lower Alloways Creek Township (Set No. l)," dated August 8, 1978, in the captioned matter, have been served upon the following by deposit in the United States mail this 8th day of August, 1978:
- Gary L. Milhollin, Esq.
Chairman, Atomic Safety and Licensfng Board 1815 Jefferson Street Madison, Wisconsin 53711 Mr. Glenn O. Bright Member, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washi~gton, D.C.
20555 Dr. James C. Lamb, III Member, Atomic Safety and Licensing Board Panel 313 Woodhaven Road
.Chapel Hill, N.C.
27514 Chairman, Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.c.
20555 Barry Smith, Esq.
Office of the Executive Legal Director U.S~ Nuclear Regulatory Commission Washington, D.C.
20555 Mark L. First, Esq.
Deputy Attorney General Department of Law and Public Safety Environmental Protection Section 36 West State Street Trenton, N.J.
0825
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2 Richard Fryling, Jr., Esq.
Assistant General Solicitor Public Service Electric
& Gas Company*
80 Park Place Newark,.N. J.
07101 R. William Potter, Esq.
Assistant Deputy Public Advocate Department of the Public Advocate Division of Public Interest Advocacy Post Of fi9e Box 141 Trenton, N. J.
08601 Sandra T. Ayres, Esq.
Department of the Public Advocate 520 East State Street Trenton, N.
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08625 Mr. Alfred C.*Coleman, Jr.
Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, New Jersey 08070 Carl Valore, Jr., Esq.
Valore, McAllister, Aron
& Westmoreland Mainland Professional Plaza '
P*. O. Box 175 Northfield, N. J.
08225 Off ice of the Secretary
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Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D. c.
20555 June D. MacArtor, Esq.
-Deputy Attorney General Tatnall Building, P. o. Box 1401 Dover,* Delaware *19901 *