ML19206A733
| ML19206A733 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/24/1976 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7904200388 | |
| Download: ML19206A733 (5) | |
Text
-
A u.
UNITED STATES OF AMERICA NUCLm.' 'l RECUL.>TGR'l CC:.a GION BEFORE TIIF iTOMIC S AFETY AND LICif: SING DOARD In the Matter of
)
)
METROPOLITAM EDISON CO'iPANY
)
Docket No. 50-320
)
E_T AL.
)
(Three Mile Island Nuclear Station,
)
)
Unit 2)
NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DCCU:'.IENTS BY IN'li_1 VENO:15 CITI7. ENS FOR A S AFE ENVIRONN:ENT/YCRK COM?.!ITTEE FOR A S.1FIi E:!VL10..:ENT w
Pursuant to 10 CFR S 2.740b. of the Commission's Rules of Practice, the Nualcar Regulatory Ce:rm.iscion Staff (St:.ff) hereb'; rec,uests that the Intervenot s Citizens for a Safe Envirenraent/ York Cc:nmittte for a Safe Environment (Intcrvenors) answer separately and fully, in u riting and under oath, the interrogatories set forth below.
Pursuant to 10 CFR 5 2.741 of the Commission's Rules of Practice, the Staff hereby requests that the Intervenors provide or produce for in-spection and copying the documents designated in the Interrogatories and replies thereto.
As used herein, the term " documents" means all writings and records cf every type in the possecsion, control or custody of the Intervenors, its G0'289
?noazooggg g
r r
. }
i INTERROGATORIES
- /
With respect to Contentions 1, 2, 3, 4 and 10.
Identify, by name and address, each individu: ' ' chom cou intend to 1.
call as a witness with respect to these contentions and state the edu-cational and professional qualifications of each such individual.
Identify each document upon which these contentions are based.
2.
Identify each document which you intend to rely upon, either in your 3.
d: rect case or as basis for cross-examination, with regard to these contentions.
Respectfully submitted,
'1,'j' jl) j l lA;.,
- gl2c-):~jldcGuri en Henty /F. -
Counuel for NRC Staff Dated at Bethesda, Maryland this 24th day of August,1976.
-*/ These are the contentions that the Applicant, Intervenors Citisens for a Safe Environment / York Committee for a Safe Environment and the Staff agreed raised environmental issues for purposes of discovery.
9 ub-290
r L
_2_
directors, members, officers, employees, counsel, censultr....s, c: agents,
I i
including, but not limited to, memoranda, correspondence, reports, sur-veys, tabulations, charts, books, pamphlets, photographs, maps, bulletins,
minutes, notes, ledgers, transcripts, ccmputer printouts, vouchers, en-gineering diagrams, recordings, telephone and telegraphic commur.ications, speeches, and all other records, written, electrical, or otherwise.
" Documents" shall also mean copies of documents, even though the originals thereof ar e not in the possession, custody, or control of the Intervenors, and every copy of a document which contains handwritten or other notations or which otherwise does not duplicate the original or any other copy.
The interrogatories attached are to be considered the Intervenors' continuing obligation. Accordingly, if, after the Intervenors have answered these inter-rogatorics, additional information comes to its attention "cith respect to cne or more of the answers, then the answers should be amended to pIovide such additional information.
The numbering of the contentions is that used by the Licensing Board in its Prehearir., Conference Order, dated November 6,1975.
60 291
a s
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of
)
)
METROPCLITAN ED13ON COMPANY,
)
Docket No. 50-320 E_T_ A__L_.
)'
)
(Three Mile Island Nucleac Station,
)
Unit 2)
.)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTICN OF DOCiJMENTS BY INTERVENORS CITIEENS FOR A SAFE ENVIRONMENT / YORK COMMITTEE FOR A SAFE ENVIROhMENT, dated August 24, 1976, in the above-captioned matter, have been served on the foll wing by deposit t
in the United States mail, first class or air mail, or, as indicated by asterisks, through deposit in the Nucl ear Regulatory Commission's internal mail system,
this 24th day of August,1976:
Edward Luton, Esq., Chairman ~
- Sidney G. Kirosley, Esq.*
Atomic Safen end Lir ensing Beard Atomic Safety d Licensing Scarci U.S. Nuclear Rc;;ulatory Ccemission U.S. Nuclea: Regulatcry Ccm-ission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Gustave A. Linenberger*
Karin W. Carter, Assistant Atomic S:::ce; ard Licersim Beard Attorney General U.S. Nuclear Regulatory Commission Office of Enforcement Washington, D.C.
20555 Department of Environmental Resources Dr. Ernest O. Salo 709 Health and <elfare Building Professer, Fisheries Research Harrisburg, Pennsylvania 17120 Institute, WH-10 College of Fisheries George F. Trowbridge, Esq.
University of Washington Shaw, Pittman, Potts & Trowbridge Seattle, Washington 98195 1800 M Street, N. W.
Washington, D. C.
20036 Mr. Chauncey R. Kepford Citizens for a Safe Environment Lawrence Sager, Esq.
25S6 Broad S'.rcet Sager & Sager Associates York, Pennsylvania 17404 45 High Sit cet Pottstown, Pennsylvania 19464 60 292
A o Mr. Chauncey R. Kepford Atomic Safety and Licensing Citizens for a Safe Environment Appea! Board" U.S. Nuclea Reguhtory Commission c/o Imeson Ranch Box 1093 Washington, D.C.
20555 Jackson, Wyoming 83001 Docheting and Service Section Atomic Safety and Licensing Office cf the Secr 2tary Board Panel
- U.S. Nucica: Regulatery Ccmmission U.S. Nuclear Regulatory Ccmmission Washington, D.C. 20555 Washington, D. C. 20555
/
s ui ^i i
i s~
Q' -
' Henrv J. ',IcGurrer.
Counsel for NRC Staff k
s
. 60~293
.