ML19289D980

Interrogatories to Safe Energy Alliance Per ASLB 790223 Order.Certificate of Svc Encl

ML19289D980
Person / Time
Site:	07002623
Issue date:	02/28/1979
From:	Ketchen E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 7903210228
Download: ML19289D980 (5)

Text

UllITED STATES OF AMERICA flUCLEAR REGULATORY COMMISSI0fl BrFORE THE ATOMIC SAFETY A!!D LICENSII;G BOARD In the Matter of

)

)

DUKE POWER C0f:PAfiY

)

)

(Amendment to Materials License

)

Docket No. 70-2623 Sf;M-1/73 for Oconee fluclear Station

)

Spent fuel Transportation and Storage )

at McGuire Nuclear Station)

)

flRC STAFF INTERROGATORIES TO SAFE EtlERGY ALLIANCE _(SEA)_ _ _ _ _ _

Pursuant to 10 CFR s2.740b the NRC Staff serves the following interrogatories on Safe Energy Alliance (SEA), Intervenor, in accordance with the Licensing Board's Order of February 23, 1979.

1.

With respect to each of your contentions set out in the stipulation of Cctober 18, 1978, as approved by the Licensing Board in its Order of February 23, 1979: /

(a) State the name, business and resident address of each person expected to be called as an expert witness at the evidentiary hearing; (b) With respect to each person named in response to interrogatory l(a), state the subject matter on which that person is expected to testify; and (c) With respect to each person named in response to interrogatory 1(a), state; (1) which contention (s) will be addressed, (2) the substance of that person's testimony 790321dM 8 and (3) what you expect the testimony to prove.

• / " Order Concerning Discovery, Contentions and Scheduling (February 23,1979)".

9 y

. 2.

With respect to each of your contentions set forth in the stipulation as approved by the Licensing Board's Order of February 23, 1979.

(a) State the name, business, and resident address of any person expected to be called as a witness at the evidentiary hearing except those already identified in response to interrogatory 1; (b) With respect to eacn person named in response to interrogatory 2(a), state the subject matter on which that person is expected to testify; and (c) With respect to each person named in response to interrogatory 2(a), state; (1) which contentions (s) will be addressed, (2) the substance of that person's testimony, and (3) what you expect the testimony to prove.

Section 2.740(e) of the Comaission's Rules of Practice states that a party is under a duty seasonably to supplement his response with respect to questions directly addressed to (i) the identity and location of persons having knowledge of discoverable natters and (ii) the identity of each person expected to be called as an expert witness at the hearing, the subject matter on which he is expected to testify, and the substance of his testimony; and to seasonably amend a prior response if he obtains information that the response was incorrect when made, or he knows that

e

. the response though correct when nade is no longer true and the circumstances mre such that failure to amend the response is i' sub<tance a kno.iing concealment.

Respectfully submitted, s v).>cn{

.,,0&e 8

L.

j Ed,;ard G. Ketchen Counsel for NRC Staff Dated at Bethesda, Maryland this y;d day of February, 1979

.e UNITED STATES OF AMERICA TiUCLEAR REGULATORY C0:,AI55 ION BEFORE THE ATOMIC SAFETY AND LICEtiSING BOARD In the flatter of

)

)

DUKE POWER COMPANY

)

Locket tio. 70-2623

)

( Amendment to Materiais License

)

SNM-1773 for Oconee fluclear Station

)

Spent fuel Transportation and Storage )

dt MCCuire iluClear Station)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES TO SAFE ENERGY ALLIANCE (SEA)", dated February 28, 1979 in the above-captioned proceeding, have been served on the following, by deposit in the United States nail, first class, or, as indicated by an asterisk through deposit in the

!!uclear Regulatory Commission's internal mail system, this 28th day of February, 1979:

• fiarshall E. Miller, Chairman Ms. Brenda Best Atomic Safety and Licensino Board Carolina Action U.S. f!uclear Requlatory Connission 1740 E. Indeoendence Blvd.

Washington, D. C.

20555 Charlotte, North Carolina 28205 Dr. Cadet H. Hand, Jr., Director Anthony Z. Roisman, Esq.

Bodega Marine Laboratory IIatural Resources Defense Council University of California 917 - 15th Street, N.W.

P.O. Box 247 Washington, D. C.

20005 Bodega Bay, California 94923 tr. Emneth A. Luebke Atomic Safety and Licensing Board U.S. fluclear Regulatory Commission Washington, D. C.

20555 Shelley B lum, Esq.

~

W. L. Porter, Esq.

418 Law Building Associate General Counsel 730 East Trade Street Legal Department Charlotte, fiorth Carolina 28202 Duke Power Company 422 South Church Street J. Michael McGarry, III, Esq.

Charlotte, North Carolina 28242 Debevoise & Liberman 1200 Seventeenth Street, fi.W.

Washington, D. C.

20036

.

• Ato:oic Safety and Licensing Appeal Board Mr. Charles Gaddy U.S. fluclear Regulatory Connission P. O. Box 2501 Washington, D.C.

20555 Davidson College Davidson,fl.C.

20036

• Atomic Safety and Licensing Board Panel U.S. fluclear Regulatory Con:nission Washington, D. C.

20555

• Docketing and Service Section U.S. iluclear Regulatory Commission Washington, D. C.

20555 f!r. Jesse L. Riley, President Carolina Environmental Study Group 854 Henley Place Charlotte, florth Carolina 28207 Richard P. Wilson, Esq.

Assistant Attorney General State of South Carolina 2600 Bull Street Columbia, South Carolina 29201 2 4>

"A )j l') r

/ l L@

L

.... /

Ed',;ard G. Ketchen Counsel for !1RC Staff