ML19262A964

Seventh Set of Interrogatories Re Intervenor Contention 13. Certificate of Svc Encl

ML19262A964
Person / Time
Site:	Zimmer
Issue date:	11/21/1979
From:	Wetterhahn M CINCINNATI GAS & ELECTRIC CO., CONNER, MOORE & CORBER
To:	MIAMI VALLEY POWER PROJECT
References
NUDOCS 7912110361
Download: ML19262A964 (8)

Text

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I \N I UNITED STATES OF AMERICA O @ $ [g 'If NUCLEAR REGULATORY COMMISSION , S, In the Matter of ) M *

)

The Cincinnati Gas & Electric ) Docket No. 50-358 Company, et al. )

)

(Wm. H. Zimner Nuclear Station) )

APPLICANT'S SEVENTH SET OF INTERROGATORIES TO MIAMI VALLEY POWER PROJECT Pursuant to 10 C.-F.R. 52.740b of the Nuclear Regulatory Commission's Rules of Practice and the Atomic Safety and Licensing Board's Memorandum and Order Ruling on Various Motions and Rescheduling Evidentiary Hearing dated October 1, 1979, Applicant, The Cincinnati Gas & Electric Company, by its attorneys, hereby propounds the following interrogatories to inter- enor, Miami Valley Power Proj ect, to be answered fully in writing, under oath, within fourteen (14) days after service hereof'in accordance with the following defini-tions and instructions:

DefinitionsandInstruhtions

1. For each interrogatory, please state the full name, address, occupation and employer of each person answering the interrogatory and designate the interrogatory or part thereof, he or she answered.

2. The following definitions shall apply: 1528 250 (a) "Intervenor" or " Project" shall mean MiamiValleyPowerProject.h 3bI 7912110 'i

S (b) " Person" shall mean an individual, person, corporation, proprietorship, partnership, or any other entity.

(c) " Identification" or " identify" when refer-ring to an individual, corporation, or other entity, shall mean that intervenor shall set forth the name, present or last known address, and if a corporation or other entity, its principal place of business or if an individual, his or her title or titles and by whom employed. Once an individual corporation, or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation, or other entity to state merely his, her or its name.

(d) " Description" or " describe" when referring to a document as hereinafter defined, shall mean that the intervenor shall set forth the author or originator, addressee (s), date, title and subject matter, the present custodian of any copy thereof and the last known address of each such custodian. In lieu of describing the document, intervenor may attach a copy thereof ta its answers, indicating the question to which the attached document is intended to be responsive. If the information requested 1528 251

in this paragraph does not appear on the face of such attached document, then intervenors shall indicate that informa-tion for each document so attached.

(e) " Document" shall mean any written, printed,

. typed or any other graphic matter of any kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of intervenor, or its officials, employees, or agents; it shall also mean all copies or drafts of documents by what-soever means made.

(f) "Date" shall mean exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the relation-ship to other events).

(g) "Zimmer Station" shall mean the Wm. H. Zimmer Nuclear Power Station.

3. These interrogatories request all knowledge or in-formation in intervenor's possession and/or knowledge and information in the possession of intervenor's agents, repre-sentatives, and, unless privileged, attorneys.

4. The following interrogatories apply to Contention 13 as admitted as an issue in controversy in this proceeding by the Atomic Safety and Licensing Board.

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4'-

Interrogatories

1. Describe any document in the possession of the Project, its consultants or proposed witnesses related to Contention 13.

2. Identify which of the documents identified in response to Interrogatory 1 the Project will seek to in-traduce into evidence and which will be used during cross-examination of the Applicant's and Staff's witnesses.

3. Identify all individuals having expertise regarding Contention 13 whom the Project has contacted or intends to contact either directly or indirectly or who has contacted the Project, directly or indirectly, regarding Contention 13 and give a summary of any information and/or opinion given by such individual with regard to Contention 13.

4. For each of the individuals identified in response to Interrogatory 3, state his home address, telephone number, present employer and address, his present occupation and position with his employer, end his education and train-ing which give him expertise with regard to Con.ention 13.

Identify all sections of the Zhmner application or other documents related to the Wm. H. Zimmer Nuclear Power Station, The Cincinnati Gas & Electric Company, Columbus & Southern Ohio Electric Company or Dayton Power & Light Company, studied or read by each individual with regard to Contention 13.

5. Identify all witnesses to be offered by the Project, giving the information requested in Interrogatory 4 if not 1528 253

already provided, and summarize the testimony to be pre-sented by each witness.

6. For each individual identified in response to Contention 3 and each member of the Project, its agents or anyone providing assistance to it, identify all individuals employed by the Applicant or other owners of the Station, their contractors and agents, or the NRC Staff, including the Office of Inspection and Enforcement, with whom contact was made by the Project or any individual identified in respense to Interrogatory 3 or 5 regarding Contention 13.

Give the dates and circumstances of each of the contacts and provide the information requested by Interrogatory 3 for each individual contacted. Summarize the substance of each contact with regard to information or opinions given or received relating to contention 13.

7. Identify all individuals which the Project intends to utilize on its behalf in the examination and cross-examination of expert witnesses pursuant to 10 C.F.R. 52.733, giving the information requested by Interrogatory 4 and setting forth any information which may tend to show that the individual has scientific or technical training or experience to so participate. If the inc.ividual's partici-pation is to be limited to a specific aspect or aspects of Contention 13, specify the limits of this participation.

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8. If not already provided, provide all independent calculations, estimates, graphics, charts, physical or mathematical models or computer codes made or utilized by the Project, its members, advisors, consultants or experts with regard to Contention 13. If the Project, its members, consultants or experts intend in the future to make or utilize any independent calculations, estimates, graphics, charts, physical or mathematical models or computer codes, whether in support of the Project's assertions or to be used in the examination of any witness, describe their intended purpose, their expected result and their expected date of completion.

9. Identify all individuals who participated in the drafting of the interrogatories to the Applicant and Staff dated November 8, 1979.

Respectfully submitted, CONNER, MOORE & CORBER Mark J. Wetterhahn Counsel for the Applicant November 21, 1979 1528 255

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

, )

The Cincinnati Gas & Electric ) Docket No. 50-358 Company, et al. )

)

(William H. Zimmer Nuclear Power )

Station) )

CERTIFICATE O. SERVICE I hereby certify that copies of " Applicant's Seventh Set of Interrogatories'to Miami Valley Power Project," dated November 22, 1979, in the captioned matter, were served upon the following by deposit in the United States mail this 22nd day of November, 1979:

Charles Bechhoefer, Esq. Michael C. Farrar, Esq.

Chairman, Atomic Safety Atomic Safety and Licensing and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Frank F. Hooper, Member Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Panel Board U.S. Nuclear Regulatory School of Natural Resources Commission University of Michigan Washington, D.C. 20555 Ann Arbor, Michigan 48109 Chairman, Atomic Safety and Mr. Glenn O. Bright, Member Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Charles A. Barth, Esq.

Coundel for the NRC Staff Richard S. Sal man, Esq. Office of the Executive Legal Chairman, Atomic Safety and Director Licensing Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 William J. Moran, Esq.

Dr. Lawrence R. Quarles General Counsel Atomic Safety and Licensing Cincinnati Gas & Electric Appeal Board -

Company U.S. Nuclear Regulatory , Post Office Box 960 Commission Cincinnati, Ohio 45201 Washington, D.C. 20555 1528 256

Mr. Chase R. Stephens Leah S. Kosik, Esq.

Docketing and Service Section Attorney at Law Office of the Secretary 3454 Cornell Place U.S. Nuclear Regulatory Cincinnati, Ohio 45220 Commission Washington, D.C. 20555 John D. Woliver, Esq.

Clermont County Community William Peter Heile, Esq. Council Assistant City Solicitor Box 181 City of Cincinnati Batavia, Ohio 45103 Box 214 Cincinnati, Ohio 45202 David Martin, Esq.

. Office of the Attorney General 209 St. Clair Street First Floor Frankfort, Kentucky 40601 Markb. Wetterhahn

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