ML20010C338
| ML20010C338 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/14/1981 |
| From: | Karman M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | JOINT INTERVENORS - CALLAWAY |
| References | |
| NUDOCS 8108190364 | |
| Download: ML20010C338 (5) | |
Text
08/14/81 f t k r>>
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
&y BEFORE TriE ATOMIC SAFETY AND LICENSING BOARD thN h[ k
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9 T'5 In the Matter of
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's KANSAS GAS A140 ELECTRIC COMPANY &
DocketNo.50-gk82 y
6 (ANSAS CITY POWER & LIGHT COMPANY
'% I,b (Wolf Creek Generating Station.
)
Unit No. 1)
)
NRC STAFF INTERR0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO WANDA CHRISTY; MARY ELLEN SALAVA AND KANSANS FOR SENSIBLE ENERGY (KASE)
INTRODUCTION AND INSTRUCTIONS The NRC Staff hereby requests that Wanda Christy, Mary Ellen Salava, and Kansans for Sensible Energy (KASE), pursuant to 10 C.F.R. 9s 2.740, 2.740b and 2.741 of the Connission's kules of Practice and the presiding Licensing Board's "Special Prehearing Conference Order," (June 3,1981) answer separately and fully, in writing under oath or affirmation, the following interrogatories and document requests.
The Staff requests that the name and address of the person or persons who provided information used in answering each interrogatory be identified, and that the source of information be disclosed where an answer is based in whole or in part on information other than the personal knowledge 01 the person or persons answering.
These interrogatories are intended to be continu*ag in nature, and tne answers should promptly be suoplemented or amended as appropriate, should Intervenors or any individual acting on their behalf cbtain any new or differing information responsive to these interrogatories.
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8108190364 810814'
{DRADOCK 05000482 m
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Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, transcript, report, hand-written notes, test data) and provide the following information as applicable:
document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also state the portion or portions of the document (whether section(s),
chapter (s), or page(s)) upon which you rely.
INTERROGATORIES 1.
With respect to each Contention advanced by Wanda Christy, Mary Ellen Salava and KASE which has been admitted by the Atomic Safety and Licensing Board in the above-captioned proceeding, list the following:
a.
A concise statement of the facts supporting each Contention together with references to the specific sources and documents and portions thereof which have been or will be relied upon to establish such facts; b.
the identity of each person expected to be called as a witness at the hearing; c.
the subject matter on which the witness is expected to testify; d.
the substance of the witness's testimony.
2.
With respect to each witness identified in the response to Interrogatory 1 above, identify each document which the witness will rely upon in whole or in part in the preparation of his testimony or in the devc'opment of his position.
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3.
With respect to each witness identified in the response to
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Interrogatory 1 above, identify the witness's qualifications to testify on the subject matter on which the witness will testify.
1 Respectfully submit ed, i
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Myro Karman Dep y Assistant Chief Hearing Counsel Dated at Bethesda, Maryland this 14th day of August,1981.
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UNITED STATES OF AMERICA V
NUCLEAR REGULATORY COMMISSION BEFORE THE~ ATOMIC SAFETY AND LICENSING BOARD lJ l
In the Matter of Docket No. 50-482
- )l KANSAS GAS AND f' ECTRIC COMPANY &
KANSAS CITY POWER & LIGHT COMPANY
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(Wolf Creek Generating Station.
Unit No. 1)
)
C_ERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF INTERR0% TORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Tf; WANDA CHRISTY; MARY ELLEN SALAVA. AND KANSANS FOR SENSIBLE ENERGY (XASE) i', the above-captioned proceeding have been served on the following by deposi'. in the United States mail, first class or, as indicated by an asterir.k, through deposit ir, the Nuclear Regulatory Commission's internal mail system, ;his 14th day of August, 1981.
James P. Gleason, Esq., Cl. airman Atomic Safety and Licensing Administrative Judge Board Panel 513 Gilmoure Drive U.S. Nuc lear Regulatory Comission Silver Spring, MD 20901 Washington, D.C.
20555
- Dr. George C. Anderson Docketing and Service Section Administrative Judge Office of the Secretary Department of Oceanography U.S. Nuclear Regulatory Comission University of Washington Washington, D.C.
20555
- Seattle, Washington 98195 Eric A. Eisen, Esq.
Dr. J. Venn Leeds Birch, Horton, Bittner & Monroe Administrative Judge 1140 Connecticut Avenue, N.W.
10807 Atwell Washington, D.C.
20036 Houston, Texas //096 Kansans for Sensible Energy Treva J. Hea ne, Esq.
P.O. Box 3192 Assistar.? General Counsel Michita, Kansas 67201 P.O. Box 360 Jefferson City, Mo. 65102 Mary Ellen Salava RoJte 1, Box 56 Jay Silberg, Esq.
Burlitigton, Kansas 66839 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washingtor,, D.C.
20006 Wanda Christy 515 N. 1st Street Burlington, Kansas 66839 i
Atomic Safety and Licensing Appeal Paard U.S. Nuclear Regulatory Comission Washington, D.C.
20555
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t C. Edward Peterson, Esq.
' Assistant General Counsel Kansas Corpuration Contission State Office Bldg.
Topeka, KS E5512 9
John M. Simpson, Esq.
Attorney for Intervenors 4400 Johnson Drive, Suite 110 Shawnee Mission, Kansas 66205 I
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=m Fi,eonfarman Depuiff Assistant Chief Hearing Counsel
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