ML19326D781
| ML19326D781 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/01/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML19326D782 | List: |
| References | |
| NUDOCS 8007030290 | |
| Download: ML19326D781 (5) | |
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NRC 7/1/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEf SING BOARD In the Matter of
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METROPOLITAN EDIS0N COMPANY,
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(Three Mile Island, Unit 1)
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4 SECOND SET OF NRC STAFF INTERROGATORIES OF UNION OF CONCERNED SCIENTISTS Pursuant to 10 C.F.R. 9 2.740b, the following interrogatories are directed to Union of Concerned Scientists.
Each interrogatory is to be answered separately and fully in writing under oath or affimation by individuals having personal knowledge of the answers.
The Licensing Board in this proceeding has directed that all responses to interrogatories must be in the hands of the discovering party 35 days after the issuance of the SER (July 21, 1980).
(The itemorandum and Order on Prehearing Conference of May 13, 1980 (May 22,1980), at 7.)
All parties are reminded that i 2.740(e) of the Commission's regulations requires parties to amend their responses when they are no longer true.
Thus,-intervenors who were not able to answer the general interrogatories submitted in the "First Set of NRC Staff Interrogatories to Intervenors" dated December 27, 1979 or the interrogatories submitted in this pleading are obligated to respond to the interrogatories upon receipt of the requested infomation.
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c All of the specific interrogatories attached refer to information contained in the Staff's "TMI-1 Restart Evaluation of Licensee's Compliance with the Short-and'Long-Term Items of.Section II of NRC Order dated August 9,1979" (SER) which was served on all parties to this proceeding on June 16, 1980.
Page numbers in the interrogatories refer to the SER.
The general interroga-tories inquire into how the parties intend to use documents, including the SER, in their presentations of evidence.
Res ectfully submitted,
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Lucinda low Swartz Counsel for NRC Staff l
Dated at Bethesda, Maryland I
this 1st day of July,1980.
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.A UCS GENERAL INTERR0GATORIES 1.
Identify by author, title, date of publication and publisher, all books, documents, and papers you intend at this time to employ or rely upon in presenting your direct case on:
a.
Contention 1 b.
Contention 2 c.
Contention 3 d.
Contention 4 e.
Contention 5 f.
Contention 6 9
Contention 7 h.
Contention 8 1.
Contention 9
- j.. Contention 10 k.
Contention 11 1.
Contention 12 m.
Contention 13 n.
Contention 14 2.
Identify by author, title, date of publication, and publisher all books, documents, or papers that you intend at this time to employ or rely upon in conducting your cross-examination of prospective NRC witnesses testifying
'in connection with:
a.
Contention 1 b.
Contention 2
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Contention 3 d.
Contention 4 e.
Contention 5 f.
Contention 6 g.
Contention 7 h.
Contention 8
.i. Contention 9 i
- j. Contention 10 k.
Contention 11 1.
Cor.tention 12
'm. ' Contention 13 n.
Contention 14 3.
If the representations made in:
a.
Contention 1
~b.
Contention 2 c.
Contention 3 d.
Contention 4 e.
Contention 5 f.
Contention 6 g.
Contention 7 h; Contention 8 1.
Contention 9
~j.'ContentionL10
- k.. Contention 11
- 1.. Contention.12-
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Contention 13 n.
Contention-14 are, based in whole or in part on any documents prepared by the HRC Staff or the licensee which you contend are deficient, specify which documents (and the particular portions) you regard as deficient and explain why they are deficient.
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