ML19029A512

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Licensee'S Request for Admissions from Mr. and Mrs. Coleman (Set No. 2)
ML19029A512
Person / Time
Site: Salem  PSEG icon.png
Issue date: 08/08/1978
From: Wetterhahn M
Conner, Moore & Corber, Public Service Electric & Gas Co
To:
Office of Nuclear Reactor Regulation
References
Download: ML19029A512 (15)
v • d • e


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION e/8/Je In the Matter of )

)

PUBLIC SERVICE ELECTRIC & ) Docket No. 50-272 GAS COMPANY ) Proposed Issuance

) of Amendment to -

(Salem Nuclear Generating ) Facility Operating Station, Unit No. 1) ) License No. DPR-70 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:

lo Intervenor, Mr. Alfred C. Coleman, Jr., has no s~ientific 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.

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2. Intervenor, Mr. Alfred C. Coleman, Jr. I does not hold himself 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, Mr. 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.

4. Intervenor, Mr. Alfred c. Coleman, Jr.,.is not a qualified individual who has scientific or technical training or experience for the purpose ~f examining or cross~xamining 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.

liiGensee requests that. intervenor, Mrs *. Alfred c.

Coleman, Jr., admit the truth of the following: -

1. *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. Alf red 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 Ce 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.

  • .I"
4.
  • Interv~nor, Mrs. Alfred c. Coleman, Jr., is

__rnot a qualified:individual.who has scientific or technical

  • . tra~ning 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 granted by the Memorandum and Order dated ~uly 18, 1978.

Respectfully submi~ted, CONNER, MOORE & CORBER

  • -~-~

MarkvJ~~:t~erhahn *

  • counsel for Licensee . * ..

A~gust 8, 1978

/

UNITED STATES OF AMERICA

.NUCLEAR REGULA-TORY COMMISSION In the Matter of )

)

PUBLIC SERVICE ELECTRIC & ) Docket No. 50-272 GAS COMPANY ) Proposed Issuance

) of Amendment to (Salem Nuclear Generating ) Facility Operating Station, Unit No. 1) ) License No. DPR-70 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 instruc~ions:

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

1. Is the contention based on one or more calcula-tions? If so:

(a). Describe each calculation and identify any documents setting

__r- .

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 performe4?

(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.

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 a:ll 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 comrnunica-tions with one or more individuals? If so:

(a) Identify by name and address each such individual.

  • (bl State the educational and professional background of .e~ch such individual, includi~g occupation and institution-al affiliai?ions.

(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 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 Ju1y*1a, 1978, and, .with respect to each person, please:

4 -

(a) State the contention or portion thereof on which he will testify;

..r (b) state the substance of facts an'd opinions to which the witness is expected to testi*fy; (c) give a:sununary of the grounds for each fact and ~pinion; and .

(d) d~scribe fully the witness' educational and professional background~

If no exper"t: witnesses have been identified or you

  • do not expect to call any expert wi t_nesses, so indicate.

Resp~ctfully submitted, CONNER, MOORE & CORBER ffJir-~

Mar:~V:t~erhahn Counsel for the Licensee A~gust 8, J..978

  • 1

. t*

UNITED STATES OF AMERICA NUCLEAR REGUL~TORY COMMISSION In the Matter of )

)

PUBLIC SERVICE ELECTRIC & ) Docket No. 50-272 GAS*COMPANY ) Proposed Issuance

) of Amendment to (Salem Nuclear Generating ) Facility Operating Station, Unit No. 1) ) License No. DPR-70 LICENSEE'S INTERROGATORIES TO LOWER ALLOWAYS CREEK TOWNSHIP (SET NO. 1)

Pursuant to 10 CFR §2.740b of the Nuclear Regulatory Corrunission'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 ( 11 LACT 11 ) , 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. For 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 individual, person, corporation, proprietorship, partnership,

or any other entity.

(c) "Identification" or "identity," when 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 ent.ity, its principal place of business or

  • if an individual his or her title or titles
  • and by whom employed. Once an individual1 c'orporation, 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

.e appear on the_ face of such attached document, then intervenor shall indicate that information for each document so attached.

. (e) "Document" shail mean any written, printed, typed or any other graphic matter of any kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, *custody~ or control of inter-venor, or its officials, employees, or *agents; i t 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 even ts) *

. 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 interrogatories 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, please supply the requested information, indicate which contention is being addressed and to which of the interrogatories or its subparts the response is being made.

INTERROGATORIES l~ Is the contention based on pne or more calcula-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 ass{gned 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 bf 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.

._,, 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 bas~d.

(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 professional backgiound 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 indi v;iduals 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 each contention granted to LACT->by the Atomic '

Safety &.Licensing Board, and, with respect to each person, p],.ease:

(a) State the contention or portion thereof on which he will testify; (b) state the substance of facts and opinions to whi_ch the witness is expected to testify; (c) give a surrunary of .the grounds for each fact

_and opinion; and (d) describe fully the witness.' educational and professional background.

If no expert witnesses have been identified-or you do

~ot expect to call any expert witnesses, so indicate.

Respectfully submitted, CONNER, MOORE & CORBER Mark J. Wetterhahn Counsel for the Licensee August 8, 1978

UNITED STATES OF AMERICA

~CLEAR REGULATORY COMMISS.

Before the Atomic Safety and Licensing Board In the Matter of )

...r

)

PUBLIC SERVICE ELECTRIC AND GAS ) Docket No. 50-272 COMPANY, et al. )

) .

(Salem Nuclear Generating )

Station, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of:

(-1). "Licensee's Request for Admissions from Mr. and Mrs.

Coleman (Set No. 2) ~ dated August 8, 1978, 1 11 (2} "Licensee's Interrogatories to Mr. and Mrs. Alfred C.

  • Coleman, Jr. (Set ~o. 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 Chairman, Atomic Safety Licensing Board Panel and Licens~ng Board U.S. Nuclear Regulatory 1815 Jefferson Street Commission Madison, Wisconsin 53711 Washington, D.C~ 20555 Mr. Glenn o .. Bright Barry Smith, Esq.

M~mber, Atomic Safety and Office of the Executive Licensing Board Panel Legal Director U.S. Nuclear Regulatory U. s.

  • Nuclear Regulatory *
  • Commission Commission Washi~gton, D.C. 20555 Washington, D.C. 20555 Dr. James c. Lamb, III *Mark L. First, Esq.

Member, Atomic Safety and Deputy Attorney General Licensing Board Panel Department of Law and 313 Woodhaven Road Public Safety

.Chapel Hill, N.C. 27514 Environmental Protection Section - .

Chairman, Atomic Safety and 36 West State Street Licensing Appeal Board Panel Trenton, N.J. 0825 U.S. Nuclear Regulatory Commission Washington, D~C. 20555

Richard Fryling, Jr., Esq.

Assistant General Solicitor Public Service Electric Carl Valore, Jr., Esq.

Valore, McAllister, Aron

  • & Westmoreland 1 -

& Gas Company ~ainlarid Professional Plaza

  • 80 Park Place p*. O. Box 175
  • Newark, .N. J. 07101 Northfield, N. J. 08225 R. William Potter, Esq. Office of the Secretary -~

Assistant Deputy Public Advocate Docketing and S~rvice Sectio~

Department of the Public Advocate U.S. Nuclear R~gulat6ry Division of Public Interest Commission Advocacy Washington, D. c. 20555 Post Office Box 141 Trenton, ~. J. 08601 . June D. MacArtor, Esq .

. Deputy Attorney General Sandra T. Ayres,. Esq. Tatnall Building, P. o. Box 1401 Department of the Public Advocate Dover, Delaware 19901 520 Ea~t State Street Trenton, N. J*. 08625 Mr. Alfred C.*Coleman, Jr.

Mrs. Eleanor G. Coleman 35 "K" Dr.j.ve Pennsville, New Jersey 08070

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