ML19211A219

First Interrogatories Directed to Intervenor La Consumers League,Inc,Per 790925 Stipulation.Requests Identification of Statutes by Title & Citations to Judicial Decisions Forming Basis for Contention 3(d).Certificate of Svc Encl

ML19211A219
Person / Time
Site:	Waterford
Issue date:	11/12/1979
From:	Glasspiegel H, Trowbridge G LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	LOUISIANA CONSUMER'S LEAGUE, INC.
References
NUDOCS 7912170209
Download: ML19211A219 (4)

Text

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November 12, 1979

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UNITED STATES OF AMERICA y

NUCLEAR REGULATORY COMMISSION

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Before the Atomic Energy and Licensing Board ~ > q

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LOUISIANA POWER & LIGHT COMPANY

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Docket 50-382

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(Waterford Steam Electric Station,

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Unit 3)

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APPLICANT'S FIRST INTERROGATORIES TO INTERVENOR LOUISIANA CONSUMERS' LEAGUE, INC.

Under the terms of the September 25, 1979 Stipulation on Discovery Schedule, approved by the Licensing Board on Septem-ber 28, 1979, it was agreed that first round discovery requests with respect to the contentions initially allowed by the Licen-sing Board would be made within 60 days of the Licensing Board's Order on contentions, dated September 12, 1979.

Applicant hereby files its first interrogatories pursuant to the approved Stipulation.

Under 10 C.F.R. Section 2.740b, these interrogatories are to be answered separately and fully in writing and under oath or affirmation.

Answers must be served on all parties and the Licensing Board.

As agreed in the Stipulation, Intervenors have forty-five (45) days to respond to this initial request, and fifteen (15) days to file objections to the interrogatory herein.

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e Interrocatory on Contention 3 3-1 Which statutes and/or judicial decisions form the basis"for Contention 3(d).

Identify statutes by title, date, and section numbers and provide cita-tions to judicial decisions.

Respectfully submitted, SHAW, PITTM N, POTTS & TROWBRIDGE By:

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G96rge F."Trowbridge' 7

Harry H.

Glasspiegel Counsel for Applicants 1800 M Street, N.W.

Washington, D.C.

20036 (202) 331-4100 Dated:

November 12, 1979 1591 081

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

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LOUISIANA POWER & LIGHT COMPANY

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Docket 50-382

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(Waterford Steam Electric Station, )

Unit 3)

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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing document, entitled " Applicant's First Interrogatories to Intervenor Louisiana Consumers' League, Inc.," were served by deposit in the U. S. mail, first class, postage prepaid, this 12th day of November, 1979, to those persons on the attached service list.

Harr'/H. Glasspieg61 U

Dated:

November 12, 1979 1591 082

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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LOUISIANA POWER & LIGHT COMPANY

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Docket 50-382

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(Waterford Steam Electric Station, )

Unit 3)

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SERVICE LIST Sheldon J. Wolfe Docketing and Service Section Atcmic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Ccmmission Washington, D.C.

20555 Washington, D.C.

20555 Henry J. McGurren, Esq.

Dr. Harry Foreman, Director Office of the Legal Director Center for Population Studies U.S. Nuclear Regulatory Box 395, Mayo Ccmmission University of Minnesota Washington, D.C.

20555 Minneapolis, Minnesota 55455 Lyman L.

Jones, Jr.

Dr. Walter H. Jordan Gillespie & Jones 881 West Guter Drive Suite 201 Oak Ridge, Tennessee 37830 1420 Veterans Memorial Boulevard Chairman, Atomic Safety and Metairie, Louisiana 70005 Licensing Board Panel U.S. Nuclear Regulatory Luke B. Fontana Ccmmission 824 Esplanade Avenue Washington, D.C.

20555 New Orleans, Louisiana 70116 Chairman, Atcmic Safety and Stephen M.

Irving Licensing Appeal Board Counsel for Petitioner U.S. Nuclear Regulatory One American Plaza Ccmmission Suite 1601 Washington, D.C.

20555 Baton Rouge, Louisiana 70825 1591 083