ML20010C199
| ML20010C199 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/17/1981 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Citizens Association for Sound Energy |
| Shared Package | |
| ML20010C198 | List: |
| References | |
| NUDOCS 8108190238 | |
| Download: ML20010C199 (8) | |
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08/17/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS _UTIL1 TIES GENERATING COMPANY, ET AL.
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Docket Nos. 50-445 50-446 (Comanche Peak Steam Electric Station, Units 1and2)
HRC STAFF'S THIRD SET OF INTERROGATORIES T0, AND REQUEST FOR DOCMENTS FROM, INTERVENOR CASE T:;e NRC Staff (" Staff") hereby requests that Intervenor CASE, pur-suant to 10 CFR 55 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or maka available for inspection and copying, all documentary material identified in the responses to interrogatories below. As pro-vided in the " Scheduling Order" issued by the Atomic Safety and Licensing Board (" Licensing Board") cn July 23, 1981, these interrogatories relate to information in the Staff's Draft Environmental Statement (DES) which is relevant to allowed contentions.
Pursuant to the Licensing Board's Scheduling Order, these interrogatories must be answered by September 11, 1981.
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 by author, title, date it was written, the qualifications kok8@K05000445 38 C10s17 0
of the author relevant to this proceeding, and the location where 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 proceeding.
INTERR0GATORIES ON CONTENTION 24 24-11.E With respect to Contention 24(a):
(a). State whether CASE contends that the Staff's DES (9 5.9) fails to adequately resolve the issue (s) raised by CASE in Contention 24(a).
(b). If the answer to Interrogatory 24-11(a) is affirmative, state in detail the reasons and basis for CASE's contention.
(c). If the answer to Interrogatory 24-11(a) is affirmative, identify all persons upon whom CASE relies in support of this contention along with a summary of their views or positions relevant to the subject matter of your contention.
M Since the first and second sets of interrogatories filed by the Staff on January 19, 1981 and March 26, 1981, respectively, covered Contention 24, the numbering of the interrogatories in this third set will begin where the second set of Interrogatories ended.
(d). If the answer to Interrogatory 24-11(a) is affirmative, identify-all persons whom CASE intends to call as witnesses in this pro-ceeding, along with a summary of their views or positions relevant to the suoject udtter of your curitention.
(e). If the answer to Interrogatory 24-11(a) is affirmative, identify all documentary or other material that CASE 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 Appleiant and/or Staff.
24-12.
WithrespecttoContention24(b):
(a) State whether CASE contends that the Staff's DES (9 5.8.2) fails to adequately resolve the issue (s) raised by CASE in Contention 24(b).
l (b). If the answer to Interrogatory 24-12(a) is affirmative, state in detail the reasons and basis for CASE's contention.
(c). If the answer to Interrogatory 24-12(a) is affirmative, identify all persons upon whom CASE relies in support of this contention along with a summary of their views or positions relevant to the subject matter of your contention.
(d). If the answer to Interrogatory 24-12(a) is affirmative, identify all persons whom CASL intends to call as witnesses in this pro-ceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
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(e)
If the answer to Interrogatory 24-12(a) is affirmative,
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identify all documentary or other material that CASE 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.
24 13.
With respect to Contention 24(c):
(a) State whether CASE contends that the Staff's DES (s 2) fails to adequately resolve the issue (s) raised by CASE in Contention 24(c).
(o). If the answer to Interrogatory 24-13(a) is affirmative, state in detail the reasons and basis for CASE's contention.
(c). If the answer to Interrogatory 24-13(a) is affirmative, identify all persons upon whom CASE relies in support of this contention along with a summary of their views or positions relevant to the subject matter of your contention.
(d). If the answer to Interrogatory 24-13(a) is affirmative, identify all persons whom CASE intends to call as witnesses in this pro-ceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
(e)
If the answer to Interrogatory 24-13(a) is affirmative, identify all documentary or other material that CASE 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 Ap;11 cant and/or Staff.
24-14.
WithrespecttoContention24(d):
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(a) State whether CASE contends that the Staff's DES (9 5.8.3.6) fails to adequately resolve the issue (s) raised by CASE in Contention 24(d).
(b). If the answer to Interrogatory 24-14(a) is affirmative, state in detail the reasons and basis for CASE's contention.
(c). If the answer to Interrogatory 24-14(a) is affirmative, identify all persons upon whom CASE relies in support of this contention along with a summary of their views or positions relevant to the subject matter of your contention.
(d). If the answer to Interro'atory 24-14(a) is affirmative, identify all persons whom CASE intends to call as witnesses in this pro-ceeding, along with a sumnary of their views or positions relevant to the subject matter of your contention.
(c)
If the answer to Interrogatory 24-14(a) is affirmative, identify all documentary or other material that CASE intends to use in this proceeding to support this contention and that you intend to offer m
as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
Respectfully submitted, M & h u % SoYkochild Marjorie Ulman Rothschild Counsel for NRC Staff Dated at Bethesda, Maryland this 17th day of August,1981 I
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,U UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEt: SING BOARD In the Matter of TEXAS UTILITIES GEllERATING COMPANY, ET AL.)
Docket Nos. 50-44 50-4,4
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(C nche Pe k team Electric Station, y
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CERTIFICATE OF SERVICE I hJreby certify that copies of "NRC STAFF'S THIRD SET OF INTERR0GA lNN TO, Af40 REQUEST FOR DOCU!1ENTS FROM, INTERVEN0R CFUR" and "NRC STAFF'S THIRD SET GF INTERRUGATURIES TO, AND REQUEST FOR DOCUt1ENTS FROM, INTERVENOR CASE" in the above-captioned proceeding have been served on the following by deposit in the United States r.wil, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail systen, or as indicated by a double asterisk, by hand delivery, or as indicated by a triple asterisk, by express mail, this 17th day of August, 1981:
Marshall E. Miller, Esq. Chairman **
Mrs. Juanita Ellis***
Administrative Judge President, CASE Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Corvaission Dallas, TX 75224 Washington, DC 20555 David J. Preister, Esq.***
Dr. Forrest J. Remick, Administrative Assistant Attorney General Judge ***
Environmental Protection Division Atomic Safety and Licensing Board P.O. Box 12548, Capital Station 305 E. Hamilton Avenue Austin, TX 78711 State College, PA 16801 Mr. Richard Fouke***
Dr. Richard Cole, Administrative Judge ** 1668-B Carter Drive Atomic Safety and Licensing Board Arlington, TX 76010 U.S. Nuclear Regulatory Commission Washington, DC 20555 Arch C. McColl III, Esq.***
701 Commerce Street Nicholas S. Reynolds Esq.
Suite 302 Uebevoise & Liberman Dallas, TX 75202 1200 17th Street, N.W.
Washington, DC 20036 Jeffery L. Hart, Esq.***
4021 Prescott Avenue Dallas, TX 75219 g7 S
II
Atomic Safety and Licensing Board Docketing and Service Section (1)*
Office of the Secretary Panel *
- U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Panel (5)*
U.S. Nuclear Regulatory Commission Washington, DC~ 20555 N
N btA bM'M Marjcfrie Ulman Rothschild Counsel for NRC Staff 4
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