ML19350B596
| ML19350B596 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/19/1981 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Rorem AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19350B597 | List: |
| References | |
| NUDOCS 8103230090 | |
| Download: ML19350B596 (4) | |
Text
,.
3/19/81 UNITED STATES OF A!! ERICA NUCLEAR REGULATORY COMitISSION BEFORE THE ATOMIC 3AFETY AND LICENSING BOARD In the Matter of
)
GENERAL ELECTRIC COMPANY)
Docket No. 70-1303
)
(Renewal of SNM-1265)
(GE Morris Operation Spent Fuel
)
Storage Facility)
)
NRC STAFF DISCOVERY REQUESTS OF INTERVEN0R R0 REM, ET AL.
f The Nuclear Regulatory Commission (NRC) Staff hereby requests that Intervenor Rorem, et al, pursuant to 10 CFR % 2.740b and in accordance with the Atomic Safety and Licensing Board's (hereafter "the Board") Order Ruling on Motion to Amend, February 19,1981 (hereaf ter " Order"), answer separately and fully, in writing under oath or affirmation, the following interrogatories within fourteen (14) days after service hereof.1/
For each response to the interrogatories set forth below, identify the person or persons who prepared or substantially contributed to the prepara-tion-of the response.
The NRC Staff further requests 1) that Intervenor Rorem, et al.,
pursuant to 10 CFR s 2.741, provide copies of, or make available for Staff 1/ n the Board's Order, the Board did not establish the time period or
_. Idate for re'sponding to the additional discovery requests.
Accordingly, it appears that the time period in 10 CFR S 2.740b(b) for responding to interrogatories applies.
10 CFR 9 2.740b(b).
8103230 tADt C-
~
, inspection and copying, the documents designated by Intervenor in response to certain of the acconpanying interrogatories and 2) that Intervenor Rorem, et al. pursuant to 10 CFR $ 2.740a, nake available for deposition in accordance with a notice of deposition under 10 CFR @ 2.740a to be filed at later date, the individuals identified in response to the Staff's a
interrogatory G-1 below.
I.
InterroaatoriesU G-1.
State whether or not you intend to call any person or persons as witnesses in this proceeding in support of (3) Contention A (c) Contention C (b) Contention B (d) Contention D and provide the names, addresses, educational backgrounds and professional qualifications of those persons you intend to call.
G-2.
Indicate which of those persons identified in respense to Interrogatory G-1 will appear voluntarily and which persons you intend to subpoena.
l
-I Interrogatories in this section should be answered with respect to each contention.
The contentions referred to are those contentions raised by Intervenor in " Additional Contentions of Rorem, et al.",
fiarch 1, 1981.
3_
G-3.
Provide sunnaries of the views, positions, or proposed testimony on (a) Contention A (c) Contention C (b) Contention B (d) Contention D of all p?rsons named in response to Interrogatory G-1 that you intend to present during this proceeding.
G-4 Identify by author, title, date of publication and publisher, all books, documents and papers that you intend to employ or rely upon in presenting your direct case on (a) Contention A (c) Contention C (b)
Contentiort B (d) Contention D and provide copies of, or make available for Staff inspection and copying, those items.
G-5.
If the representations made in (a) Contention A (c) Contention C (b) Contention B (d) Contention D are based in whole or in part on any documents prepared by the Licensee or NRC Staff which you contend are deficient, identify the documents and specify the particular portions thereof you regard as deficient and explain why they are deficient.
G-6.
Identify by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in
. conducting your cross-exanination of prospective NRC Staff wi:qesses testifying in connection with (a) Contention A (c)
Contention C (b) Contention B (d)
Contention D II.
Request for Deposition The NRC Staff hereby requests that pursuant to 10 CFR 9 2.740a, Intervenor Rorem, et al. nake available for deposition (upon a notice of deposition to be filed by the Staff at a later date in accordance with 10 CFR 9 2.740a) all of the individuals identified in response to the Staff's interrogatory G-1 above.
Respectfully subnitted, M
bA b[kac/u.M Marjorie Ulnan Rothschild Counsel for NRC Staff Dated at Bethesda, Maryland this 19th day of flarch, 1981