ML19029A744

Transmittal of Notice of Deposition

ML19029A744
Person / Time
Site:	Salem
Issue date:	06/05/1978
From:	Wetterhahn M Conner, Moore & Corber, Public Service Electric & Gas Co
To:	Potter R Office of Nuclear Reactor Regulation, State of NJ, Dept of the Public Advocate
References
Download: ML19029A744 (5)

Text

LAW OFFICES CoNNER.MooRE & CoREER TROY B. CONNER, JR, ARCH A. MOORE. JR~

ROBERT J. CORBER MARK J. WETTElUIAlfN DON.A.LO J. BALSLEY, JM.

J. ROY SPRA014MY, Jff, KEITH I[. ELLIS

~OT A.DICITTSD JN D*C* CABLE ADDRESS: ATOMLAW R. William Potter, Esq.

Assistant Deputy Public Advocate *1 Department of the Public Advocate  !

I Division of Public Interest Advocacy Post Off ice Box 141 Trenton, New Jersey 08601 In the Matter of Public Service Electric & Gas Company, et al.

(Salem Nucle. ar Generat~!lg-- ..-B't'Cifi~, *.Unit 1)

. Docket No,.-~* 50-272 ) ___..,,.-- *

Dear Mr. Potter:

As neither you nor.your co-counsel have responded to my attempts to arrange a convenient time for you to make your clients and potential witness available for the taking of depositions, I am transmitting to you the enclosed "Notice of Deposition."

Sincerely, ,

g;cJfjfD~

Mark Jo Wetterhahn Counsel for the Licensee MJW/mwm Enclosure cc: 9ary L. Milhollin, Esq.

Mr. Glenn O. Bright Dr. James C. Lamb, III Chairman, Atomic Safety and Licensing Appeal Board Panel Chairman, Atomic Safety and Licensing Board Panel Barry Smith, Esq.

Mark L. First, Esq.

~ichard Fryling, Jr., Esq.

William C. Horner, Esq.

June D. MacArtor, Esq.

Office of the Secretary, NRC

...* -- ',***:~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.

In the Matter of )

)

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

) Amendment tq Facil.ity (Salem Nuclear Generating ) Operating License No. DPR-70)

Station, Un~t No. 1) )

NOTICE OF D.EPOSITION TO: Mr. Alfred -c* *. Coleman, Jr. Mrs. Eleanor G. Coleman 35 "K" Drive 35 11 K11 Drive Pennsville, New Jersey 08070 Pennsville, New Jersey 08070 and Any other persons in the classes or groups described herein.

This notice, as permitted by 10 CFR 2.740a in circumstances whe+e, as here, names and addresses of persons to be examined are not known, is directed to, in addition to Mr. & Mrs. Alfred C. Coleman, Jr. {collectively "Intervenor"), persons who comprise the classes or groups described below. The persons to be ex-amined thus include, in addition to Mr. & Mrs. Coleman, all such persons in the descri~ed classes or groups, as follows:

1. Each individual who contributed in any substantive manner to the preparation of the following:

Paragraphs 2A and B, 6, and 9A through D of "Amended Petition to Intervene" of Alfred c.

Coleman, Jr. and Eleanor G. Coleman, dated May 11, 1978.

2. Each individual who Intervenor plans, proposes or expects will be a witness for it in this proceeding.

3. Each individual (other than an attorney) who Inter-verior plans, proposes, or expects will:

(a} Be an ~nterrogator, spokesman or representative for i t at any public hearing in this proceeding; or (b) Furnish it expert advice or otherwise consult with it in -regard to preparation of direct evidence, including testimony and exhibits and preparation of cross-examination for any public hearing in this proceeding.

The above-named or described persons are hereby notified, pursuant to 10 CFR 2.740a, that Public Service Electric and Gas Company, by and through its counsel 1 will take the oral deposition of Alfred C. Coleman, Jr. on Wednesday, June 28, 1978, from 9:00 a.m. until 11:00 a.m., or until completed, of Eleanor G. Coleman on Wednesday, June 28, 1978, from 11:00 a.m. until 1:00 p.m., or until completed; and of all other persons described herein, in alphabetical order, commencing on Wednesday, June 28, 1978, at 2:00 p.m. and 4:00 p.m., and continuing on Thursday, June 29, 1978, at 9:00 a.m., 11:00 a.m., 2:00 p.rn., and 4:0G p.m.,

respectively, and on each subsequent normal business day there-after until completed.

All depositions will be taken at 80 Park Place, Newark, N.J. Q7101. The depositions will be taken before Adler Reporting Service, Certified Shorthand Reporter and Notary Public of the State of New Jersey, whose address is 40 East Park Street, Newark, New Jersey 07102.

Each examination will relate to the contentions identified as issues for hearing in the captioned proceeding in the 11 0rder

Followi~g Prehearing Conference'l of the Atomic Safety and Licensing Board presiding herein, dated May 24, 1978, at pp.

s-10.

The deposition of each deponent will be taken, as appro-priate, with regard to the following:

1. His or her interest in this proceeding and the facts relating thereto;

2. His or her knowledge of the admitted contentions and the supporting basis and other facts relating thereto;

3. The subject matter on which each prospective witness for Intervenor is expected to testify, his or her educational and professional qualifications to give expert opinion testimony, and the substance of his or her testimony;

4. The educational, professional, and any other relevant qualifications of any proposed interrogator, spokesman, or representative for Intervenor in the evidentiary hearing (other than an attorney appearing as such) ,

and the subject matter and substance of what he or she plans to elicit;

5. The subject matter and substance of any other direct or cross-examination evidence, including exhibits, which Intervenor plans to adduce or elicit in this proceeding; and *

6. The names and identities, addresses, educational, professional, and other relevant qualifications of all other individuals from whom Intervenor has or will obtain information, expert opinion, facts or other matters.

Each deponent should bring to the deposition session the whole of all documents and other material pertinent to the fore-going upon which he or she relies in whole or in part, and should

be prepared. to des~gnate sp~cific portions of documents or'"

oth~r material upon which he or she reli~s.

Mark J. Wetterhahn CONNER, MOORE & CORBER Counsel for the Licensee 1741 Pennsylvania Avenue, N.W.

Washington, D.C~ 20006 (202) 833-3500 Date: June 5, 1978