ML20010C187
| ML20010C187 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/13/1981 |
| From: | Sherwin Turk NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | LOUISIANA CONSUMER'S LEAGUE, INC. |
| Shared Package | |
| ML20010C188 | List: |
| References | |
| NUDOCS 8108190227 | |
| Download: ML20010C187 (9) | |
Text
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8/13/81 UNITED CATES OF A!1 ERICA fiUCLEAR REGULATORY C0f1HISSION BEFORE THE ATOMIC SAFETY AtlD LICENSING BOARD In the Matter of LOUISIAhA POWER AllD LIGHT COMPANY Docket tio. 50-382 (Waterford Steam Electric Station, )
Unit 3)
)
HRC STAFF'S THIRD SET OF INTERR0GATORIES TO, AND REQUEST FOR DOCUMENTS FROM, LOUISIANA C0f4SUMERS LEAGUE, INC.
The liRC Staff (" Staff") hereby requests that Louisiana Consumer's League, Inc. ("LCL"), pursuant to 10 CFR 69 2.740b and 2.741, answer separately and fully, in writing under Mth or affirmation, the following interrogatories and produce or make available for inspection and copying, all documentary material identified in the responses to interrogatories below. As provided in paragraph 3 of the " Stipulation on Discovery Schedule" (" Stipulation)",
forwarded to the Atomic Safety aad Licensing Board (" Licensing Board") on September 25, 1979, these interrogatories relate to new information contained in the Staff's Safety Evaluation Report (SER) relevant to allowed contentions.
Pursuant to paragraph 5 of the Stipulation, these interrogatories must be answered within 30 days, and any objections to the interrogatories must be served within 15 days.
All references provided in response to these interrogatories are to be identified by author, title, date of publication and publisher if the reference is published; if any such reference is not published, it is to be ' identified n100190227 M h 2 pU 74
.PDR ADOCK ppg o
=
by author, title, date it was written, the qualifications of the author rele-vant to this proceeding, and the location wnere a copy of the document may be obtained.
All persons named in response to these interrogatories are to be identi-fied by name, address, employer, position, education, professional qualifica-tions, and publications related to their views concerning the subject matter of this pt
'ng.
4 INTERROGATORIES ON CONTENTION 2 2-1. State whether LCL contends that the Staff's SER (99 2.2, 7.2.5, 8.2, 8.3) fails to adequately resolve the issue (s) raised by LCL in Conten-tion 2.
2-2. If the answer to Interrogatory 2-1 is affirmative, state in detail the reasons and basis for LCL's contention.
2-3. If the answer to Interrogatory 2-1 is affirmative, identify all persons upon whom LCL relies in support of this contention along with a summary of their views or positions relevant to the subject matter of your contention.
2-4. If the answer to Interrogatory 2-1 is affirmative, identity all persons whom LCL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter 1
of your contention.
I e
e 2-5. If the answer to Ir.tarrogatory 2-1 is affirmative, identify all documentary or other material that I.CL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
INTERR0GATORIES ON CONTENTION 3 3-1. State whether LCL contends that the Staff's SER (99 2.1, 2.2) fails to adequately resolve the issue (s) raised by Contention 3.
3-2. If the answer to Interrogatory 3-1 is affirmative, state in detail the reasons and basis for LCL's contention.
3-3. If the answer to Interrogatory 3-1 is affirmative, identify all persons upon whom LCL relies in support of this contcation, along with a summary of their views or positions relevant to the subject matter of this contention.
3-4. If the answer to Interrogatory 3-1 is affinnative, identify all persons whom LJL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
e
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3-5. If the answer to Interrogatory 3-1 is affirmative, identify all documentary or other material that LCL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses pre-sented by the Applicant and/or Staff.
INTERR0GATORIES ON CONTENTION 4 4-1. State whether LLL contends that the Staff's SER (i 13.3) fails to adequately resolve the issue (s) raised by Contention 4.
4-2. If the answer to Interrogatory 4-1 is affirmative, state in 4
detail the reasons and basis for LCL's contention.
4-3. If the answer to Interrogatory 4-1 is affirmative, identify all persons upon whom LCl relies in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
4-4. If the answer to Interrogatory 4-1 is affirmative, identify all persons whom LCL intends to call as witnesses in this proceeding, along 4
with a summary of their views or positions relevant to the subject matter of your contention.
l l
4-5. If the answer to Interrogatory 4-1 is affirmative, identify all l
l documentary or other material that LCL intends to use in this proceeding -
to support this contention and that you intend to offer as exhibits on
this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
INTERR0GATORIES ON CONTENTION 6 6-1. State whether LCL contends that the Staff's SER (il 15.2,15.3) fails to adequately resolve the issue (s) raised by Contention 6.
6-2. If the answer to Interrogatory 6-1 is affirmative, state in detail the reasons and basis for LCL's contention.
6-3. If the answer to Interrogatory 6-1 is affirmative, identify all persons upon whom LCL ~ elies in support of this centention, along with a r
summary of their views or positions relevant to the subject matter of this contention.
6-4. If the a7swer to Interrogatory 6-1 is affirmative, identify all persons whon. LCL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
6-5. If the answer to Interrogatory 6-1 is affirmative, identify all documentary or other material that LCL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses pre-sented by the Applicent and/or Staff.
INTERROGATORIES ON AMENDED CONTENTION IU 1A-1.
State whether LCL contends that the Staff's SER ($ 17.1-6, 22.2) fails to adequately resolve the issue (s) raised by Amended Contention 1.
1A-2.
If the answer to Interrogatory 1A-1 is affirmative, state in detail the reasons and basis for LCL's contention.
1A-3.
If the answer to Interrogatory 1A-1 is affirmative, identify all persons upon whom LCL relies-in support of this contention, along with a summary of their views or giositions relevant to the subject matter of this ontention.
4 1A-4.
If the answer to Interrogatory 1A-1 is affirmative, identify all persons whom LCL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
IA-5.
If the answer to Interrogatory 1A-1 is affirmative, identify all doc;mentary or other material that LCL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses pre-sented by the Applicant and/or Staff.
O All references herein to any " Amended Contention" relates to the " Amended Contentions of the Louisiana Consumer's League, Inc.," filed on December 10, 1979.
INTERROGATORIES ON AMENDED CONTENTION 2 2A-1.
State whether LCL contends that the Staff's SER (il 15.2, 15.3,22.2) fails to adequately resolve the issue (s) raised by Amended Contention 2.
2A-2.
If the answer to Interrogatory 2A-1 is affirmative, state in detail the reasons and basis for LCL's contention.
2A-3.
If the answer to Interrogatory 2A-1 is affirraativo, identify r
all persons up]n whom LCL relies in support of this contention, along with 4
a summary of their views or positions relevant to the subject matter of this contention.
i 2A-4.
If the answer to Interrogatory 2A-1 is affirmative, identify all personr. whom LCL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
2A-5.
If the answer to Interrogatory 2A-1 is affirmative, identify all documentary or other material that LCL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to a.cfer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
6 3
d' b
l INTERROGATORIES ON AMENDED CONTENTION 3 3A-1.
State whether LCL contends that the Staff's SER (il 15.2, 15.3, 22.2) fails to adequately resolve the issue (s) raised by Amended Conten-tion 3.
3A-2.
If the answer to Interrogatory 3A-1 is affirmative, state in detail the reasons and basis for LCL's contention.
3A-3.
If the answer to Interrogatory 3A-1 is affirmative, identify all persons upon whom LCL re' lies in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
3A-4.
If the answer to Interrogatory 3A-1 is affirmative, identify all persons whom LCL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
3A-5 If the answer to Interrogatory 3A-1 is affirmative, identify all documentary or other material that LCL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
I i
6
INTERROGATORIES ON AMENDED CONTENTION 4 4A-1.
State whether LCL contends that the Staff's SER (il 12.3, 15.4,22.2) fails to adequately resolve the issue (s) raised by Amended Con-tention 4.
4A-2.
If the answer to Interrogatory 4A-1 is affirmative, state in detail the reasons and basis for LCL's contention.
4A-3.
If the answer to Interrogatory 4A-1 is affirmative, identify all persons upon whom !CL reiies in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
4A-4 If the answer to Interrogatory 4A-1 is affirmative, identify all persons w'iom LCL intends to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
4A-5.
If the answer to Interrogatory 4A-1 is affirmative, identify all documentary or other material that LCL intends to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
Respectfully submitted, ih L W Sherwin E. Turk Counsel for NRC Staff Dated at Bethesda, Maryland this 13th day of August, 1981 l
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