ML19210E063
| ML19210E063 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 10/30/1979 |
| From: | Leed R LEED, R.M. |
| To: | PUGET SOUND POWER & LIGHT CO. |
| Shared Package | |
| ML19210E064 | List: |
| References | |
| NUDOCS 7911290250 | |
| Download: ML19210E063 (10) | |
Text
-
.y.
c, q.
s I)0 C b M g 0 0 %
/f n
55'
~
1G0 TO aELmn r w...m. ece7,,g.
[
g gT37 %
gi
-s UNITED STATES OF AMERICA yo d [i,' c#
e NUCLEAR REGULATORY COMMISSICN o
wi S
o DI T
BEFORE THE ATCMIC SAFE'2Y AND LICENSING BCARD I ;.y V In the Matter of
)
)
PUGET SCUND POWER & LIGHT
)
DOCKET N05.
STN 50-522 COMPANY, et al.,
)
50-523
)
(Skagit Nuclear Power Project, )
Units 1 and 2)
)
Octobe r 30, 1979
)
)
INTERRCG ATORIES TO APPLICANT REG ARCING SAN JUAN ISLANDS SEISMIC PROFILES The purpose of these interrogatories is to determine when and by what means the Applicant le arned of the exis-tence and content of the seismic profiles of the San Juan Islands produced oy Western Geophysical in 1971 and other data relevant to the San Juan features; and to determine when and by what me,ans Applicant provided these data to the NRC S taf f andd USGS.
This information is scught in order to determine whether Applicant has made a material false statement, as that term is used in Section 135 cf the Atomic Energy Act, 42 U.S.C.
5 2 236.
In accordance with 10 CFR 52.740(b) and 10 CFR S2.741, please answer the following Interrogatories and respond to the accompanying P ' ' ests for Production.
Documents be produced should be presented at the of-fices of undersigned counsel at 5:00 p.m.,
November 26, 1979, or at such cther time and place as may be agreed upon. }k20
,J i l 2 9 0 o ~, 5 c) 4
s As used herein, the term " document" means all writings and records of every type in the possession or control of Applicant or its directors, officers, members, ecployees, attorneys, consultants, agents or representatives, including, but not limited to, memoranda, correspondence, reports, s u r vey s, charts, books, photographs, maps, notes, studies, drawings, writings, minu tes, computerized data or printouts, notes of telephone conversations, notes of meetings or other conversations, and all other records.
DATED this 40% day of
[w - Ns_ v 1979.
r/
ROGER M.
LEED v
,,f, ~i l,r,
- ,,,1 i
a I, i*.
By
.u
- w. t?.,4 _f.
1428 297.-.-
INTERRCG ATORY NO. 1:
On what date did Puget S ou nd P ow e r
& Light Ccmpany or any of its agents, attorneys, or consul-tants, including Dr. Milton Dobrin, become aware of the exis-tence of the 1970 study done by Western Geophysical for Mobil Oil, surveying the ocean floor in the straits of Georgia?
AN SWER:
INTERECG ATORY NO. 2.
Please state the manner in which Puget Sound Power & Light Cc=pany or any of its agents, at-torneys, or consultants, including D r.
Milton Dobrin becace aware of the study, the source of the information, and the name or names of the persons at Puget who received the infor-mation.
ANSWER:
INTERROGATORY NO. 3:
When did Puget Sound Power &
Light Company or any of its agents, attorneys, or consultants, including D r. Milton Dobrin, learn of the contents of the 1970 study perf ormed by Western Gecphysical for Mobil Oil?
ANSWER:
~~
e
INTERROG ATORY NO. 4:
Please state the T.anner in which Puge Sound Pcwer & Light Company or any of its agents, at-torneys, or consultants, including D r. Milton Cobria, became aware of the study, the source of the information, and the name or names of the persons at Puget who received the infor-mation.
ANSWER:
INTERRCGATORY NO. 5 :
On what date did Puget Sound Power
& Light Company or any of its agents, attorneys, or consul-tants, including Dr. Milton Dobrin, obtain a copy of the 1970 study referenced in interrogatory no.
1, and from whom was it cbt,21nec?
ANSWER:
INTERRCG ATORY NO. 6:
Please answer the foregoin~v interrogatories nos. I through 5 with respect to the 1971 study of seismic profiles in the S an Juan Islands perf ormed.
by Western Geophysical.
/7p
'OO Ifco
/_ / /
_4_
..;...,,n-
., ~ n
..,.,x,.r. m s.u m m,
z..
.. ~ ~... -.
a INTERRCG ATORY NO.
7.
With reference to the study ccomis-sioned by Puget Sound Power & Light Company from Western G ecp hy sical, please state the dates on which the study was commissioned, completed, and made available to Puget Sound Pcwer & Light Company.
ANSWER:
INTSRRCGATORY NO. 3:
Please state with respect to each of the three studies referenced in these interrogatories:
a.
When Puget Sound Power & Light Company or any of its agents, attorneys, or consultants, communicated the existence of each study to the NRC Staff.
b.
When Puget Scund Power & Light Ccepany or any of its agents, attorneys, or consultants, communicated the existence of each study to the United S tates Geologic Survey.
c.
When Puget Sound Power & Light Company cr any of its agents, attorneys, or consultants, communicated the centents of each study to the NRC Staf f.
d.
When Puget Sound Pcwer & Light Ccapany or any of its agents, attorneys, or consultants, ccc=unicated the contents of each study to the United S tates Geologic Survey.
e.
The date on which Puget Scund Power & L igh t C cap any or any of its agents, attorneys, or consultants, provided a copy of each study to the NRC S taf f.
_5_
~
. =
-,.,,gg
_.y,,,
9
_.4
=g
.,.g g y
,, =*
g,,, e g*.
6 g
+,
f.
The date on which Puget Sound Power & Light Company or any of its agents, attorneys, or consultants, provided a copy of each study to the United States Geologic Survey.
ANSWE R:
INTERROGATORY NO. 9:
With respect to subparts (a) through (f) of the foregoing interrogatory (Interrogatory No.
- 8) please furnish the name or names of each employee of or person retained by Puget Sound Power & L igh t C omp an; or other person who communicated the inf ormation to the NRC Staf f or to the U.S.G.S.,
the matter in which the information was communi-cated, and the name or names of the persons with'.n the NRC S taf f or the U.S.G.S. who: Puget Sound Power & Light C omp any knows ce has to reason to believe was made aware of the existence or contents of the information, or who has been provided copies of the data.
ANSWER: 1428 301
..~=,,,_,......,.~.n a,m.n.m m.,
INTERRCG ATORY NO. 10 Please furnish the name of each person who was in the employ of or retained by Sechtel c:
Puget Sound Power & Light Company, at any time subsecuent to 1970, and who at any time was employed by, retained by, or associated in any manner with Western Geophysical or Mobil 011.
ANSWER:
INTERRCGATORY NO. 11:
For each person listed in response to Interrogatory No. 10, please state:
(a) the dates on which such person was associated with Bechtel or Puget; (b)
.,the nature of the association; (c) whether and when such persen was aware of the exis-tence or contents of the studies perf ormed by Western Gec-physical, or had in their possession a copy of each c: any study; (d) the dates on which such person was associated with Western Geophysical or Mobil Oil; (e) the nature of the association; (f) whether and in what ca.mner such person <as involved in performing the studies; and 1428 302 p
(g) whether, in wha: manner, and when such person com-municated the existence of, contents of, or provided copies of any of the 3 studies.
,. o.v R :
INTERRCGATORY NO. 12.
Please state whether Mil:On D0b:in participated in perf orming any of the studies for Western Geo-physical, or was awa:e of the existence of or contents of these studies, and whether, when, in what manner, and to whom, D.
Dobrin communicated the existence, contents, or made copies available of these studies to Puget or Bechtel.
ANSWER:
1428 303
_3_
~.. ~,...,.
u a., a s.m.w. xm+,w:m., a a
7,.
..o.r.G n.
0 a-v.
.go.
1,.
- o..,. 2 o.
.-.....o....c,,
4
.e s.
what manner, and from whom Merly.n J. Adair learned of the existence of, contents of, or was p cvided copies of any or all of the three studies perf ormed by Western Geophysical.
ANSNER:
INTERROGATORY NO. 14.
Please state the names of all persons within Western Geo.chv. sical, Mobil Oil, Bechtel, P u c. e t,
the U SG S, and the NRC Staff with whom Mr. Adair communicated, and p rovide the da tes of such co.TT.unica tions, regarding any studies perf ormed by Western Geophysical relating to San Juan Island features.
n,SasR:
1428 304
_9_
- N!dR200ATORY NO. 15-Pie 2se descrite specifically ali internal and external communications, whether or not reflected in any written records, by or to Puget or Bechtel or Dr. Milton Dobr_n, which in any way relate to the 1970 Mc7il seismic study above identified, the 1971 Weetern Geophysical study above identified, and the Western Geophysical study conducted f or Puget.
c.J, o-.. R :
ac 3
REQUIST FOR PRODUCTICN NC. 1:
Please p 0 duce fcr inspec-tion and copying any and all documents which are described in answers to, or contain in:ccmation re.3evant to the :.oregoing interrogatories and any or all dccuments used by Puge: Sound r
?cwer & Light Company in preparing responses to the f oregoing inter:cgatories.
_,a_
sJ 1428 305
..,..