ML19350B599
| ML19350B599 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/19/1981 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | ILLINOIS, STATE OF |
| Shared Package | |
| ML19350B597 | List: |
| References | |
| NUDOCS 8103230095 | |
| Download: ML19350B599 (4) | |
Text
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O 3/19/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of GENERAL ELECTRIC COMPANY)
)
Docket No. 70-1308 (GE Morris Operation Spent Fuel Storage Facility)
)
NRC STAFF DISCOVERY REQUESTS OF INTERVENOR THE STATE OF ILLIN0IS The Nuclear Regulatory Comnission (NRC) Staff hereby requests that Intervenor the State of Illinois (hereafter "Intervenor" or " Illinois")
pursuant to 10 CFR 6 2.740b and in accordance with the Atonic Safety and Licensing Board's (hereafter "the Board") Order Ruling on Motion to Amend, February 19, 1981 (hereafter " Order"), answer separately and fully, in writing under' oath or affimation, the following interrogatories within fourteen (14) days after service hereof.1/
For each response to the interrogatories set forth below, identify the 4
person or persons who prepared or substantially contributed to the prepara-tion of the response.
- The NRC Staff further requests 1) that Intervenor pursuant to 10 CFR 9 2.741, provide copies of, or make available for Staff inspection and 1/ n the Board's Order, the Board did not establish the time period or I
date for responding to the additional discovery requests.
Accordingly, it appears that the time period in 10 CFR 6 2.740b(b) for responding to interrogatories applies.
10 CFR 6 2.740b(b).
- s1os 23 0 095V.
. copying, the documents designated by Intervenor in response to certain of the accorpanying interrogatories and 2) that Intervenor pursuant to 10 CFR 9 2.740a, nake available for deposition in accordance with a notice of deposition under 10 CFR 5 2.740a to be filed at a later date, the individuals identified in response to the Staff's interrogatory G-1 below.
I.
Interrocatories_/
2 G-I.
State whether or not you intend to call any person or persons as uitnesses in t'lis proceeding in support of (a) Contention 1 (c) Contention 3 (b) Contention 2 (d) Contention a (e) Contention 5 and provide the names, addresses, educational backgrounds and professioral qualifications of those persons you intend to call.
G-2.
Indicate which of those persons identified in response to Interrogatory G-1 will appear voluntarily and which persons you intend to subpoena.
2_/ Interrogatories in this section should he answered with respect to each contention.
The contentions referred to are those contentions raised by Intervenor in " Additional Contentions of The State of Illinois", February 25, 1981.
I i G-3.
Provide summaries of the views, positions, or proposed testimony on (a) Contention 1 (c) Contention 3 (b) Contention 2 (d) Contention 4 (e) Contention 5 of all persons named in response to Interrogatory G-1 that you intend to present during this proceeding.
I 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 1 (c) Contention 3
- (b) Contention 2 (d) Contention 4 (e) Contention 5 4
and provide copies of, or make available for Staff inspection and copying, those items.
1 G-5.
If.the representations made in i
(a) Contention 1 (c) Contention 3 (b) Contention 2 (d) Contention 4 (e) Contention 5-
.are based in whole or.in part on any documents prepared by the Licensee or.
NRC Staff which youf contend are deficient, identify.the documents and specify.the particular portions thereof you regard as deficient and explain
_ why they are deficient.
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4-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 j
conducting your cross-exanination of prospective NRC Staff witnesses tescifying in connection with I
(a) Contention 1 (c) Contention 3 i
(b) Contention 2 (d) Contention 4 i
(e) Contention 5 II.
Request for Deposition The NRC Staff hereby requests that pursuant to 10 CFR 5 2.740a, Intervenor nake available for deposition (upon a notice of deposition to i
be filed by the Staff at a later date in accordance with 10 CFR Q 2.740a) l all of the individuals identified in response to the Staff's interrogatory F
G-1 above.
Respectfully subaitted, I
bw bbc04.M tiarjorie U1 nan Rothschild Counsel for NRC Staff Dated at Bethesda, flaryland this 19th day of March,1981 i
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