ML19029A562

Licensee'S Request for Admissions from Mr. and Mrs. Coleman

ML19029A562
Person / Time
Site:	Salem
Issue date:	06/28/1978
From:	Wetterhahn M Conner, Moore & Corber, Public Service Electric & Gas Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML19029A562 (3)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the* Matter of )

)

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

) 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 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 sGientific or technical training, experience and/or other expertise.with regard to the contentions* which were

. granted in the "Order Following Special. Prehearing Confer-ence" dated May 24, 1974.

2. Intervenor, Mr. Alfred c. Coleman, Jr., does not hold himself out as an expert with regard to ;;i,ny of the

... "1..i.

contentions which were granted in the "Order Following Special Prehearing Conference" dated May 24, 1978.

3. Intervenor, Mr. *Alfred C. Coleman, Jr., will not seek to become an expert witness with regard to any of the contentions which were granted in the. "Order Following Special Prehearing Conference" dated May 24, 1978.

4. Intervenor, Mr. Alfred c. Coleman, Jr., is not a qualified individual who' has scientific or technicai training or experience for the purpose of examining or cros~examining expert witnesses pursuant to 10 CFR' §2.733.

LiGensee 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 the contentions which were granted in the "Order Following Special Prehearing Confer-ence" dated May 24, 1978.

2. Intervenor, Mrs. Alfred C. Coleman, Jr., does not hold herself out as an expert with regard to any of the contentions which were. granted in the "Order Following Special Preheari~g Conference" dated May 24, 1978.

3. Intervenor, Mrs. Alfred c. Coleman, Jr., will not Seek to become an expert witness with regard to any of the contentions which were granted in the "Order Following

Special Prehearing Conference" dated May 24, 1978.

4. Intervenor, Mrs. Alfred c. Coleman, Jr., is not a qualified*individu~l who has scientific or technica.l training or experience for the purpose of examining or crossexamining expert witnesses pursuant to 10 CFR §2.733.

Respectfully submitted, CONNER, MOORE & CORBER 1fl~M~YJL Mark ;~~hahn Counsel for Licensee June '28, 1978.