ML20027B563
| ML20027B563 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 09/17/1982 |
| From: | Cavanagh R CAVANAGH, R., National Resources Defense Council |
| To: | PUGET SOUND POWER & LIGHT CO. |
| References | |
| NUDOCS 8209210289 | |
| Download: ML20027B563 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of PUGET JOUND POWER & LIGHT
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Nos. STN 50-522, 50-523 COMPANY, -et al.
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(Skagit/Hanford Nuclear
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Project, Units 1 and 2)
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Date:
September 17, 1982 _-
NATURAL RESOURCES DEFENSE COUNCIL'S FIRST SET OF INTERROGATORIES TO APPLICANTS s
The Natural Resources Defense Council (NRDC) hereby serves its First Set of Interrogatories to the Applicants pursuant to 10 C.F.R. S 2.740b.
Edch interrogatory is to be answered fully in writing, under oath or affirmation, by an officer or agent of Applicants and is to include all pertinent information known to Applicants.
Each answer sbculd clearly indicate the s
interrogatory to which it is intended to be responsive.
Under NRC regulations (10 C.F.R.
S 2.740(e)) parties are required to supplement responses to interrogatories under certain circumstances when new and/or different information becomec available.
Applicants are obligated to comply with this re}guire-ment with respect to its answers to NRDC's First Set of
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Interrogatories.
" Applicants" shall include all agents, eAployees, attorneys, investigators, and all other persons direct,1y or indirectly
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subject to Applicants' control in any way.
"You" and "Yours" refers to Applicants.
" Documents" means all written or recorded material of any kind or charact'er known to Applicants or in their possession, custody, or control, including, without limitation, letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records or notation of telephone or personal conversations or conferences, inter-office communications,
' microfilm bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings, computer printouts, and work-sheets.
.When used with respect to a document, " identify" means, without limitation, to state its date, the type of document 3
I (e.g.,
letter, memorandum, telegram, chart, photograph, sound reproduction, etc.), the author and addressees, the present location and custodian, and a description of its contents.
When used with respect to a person, identify" means, without limitation, to state his or her name, address, and occupation.
If Applicants cannot answer any portion of'any'of the
'interro atories in full, after exercising due diligence to do so, so state, and answer to the extent possible, specifying the inability to answer the remainder and stating when Applicants expect to be able to answer the unanswered portions.
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INTERROGATORIES 1.
With respect to the NRDC contentions as phrased and admitted by the Licensing Board in its Memorandum and Order of July 6, 1982, identify all of Applicants' bases for opposing each contention.
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2.
With respect to each basis identified in your answer to Interrogatory 1, state whether the basis is supported by:
A.
One or more documents.
B.
Any type of study, calculation, or analysis.
C.
Research.
D.
Conversations, consultations, correspondence, or any other type of communications with one or more individuals.
3.
If your answer to Interrogatory 2 is one or more documents:
A.
Identify each such document.
Identify the information in each document which B.
supports the basis.
C.
Explain how such information provides support for the basis.
4 If your answer to Interrogatory 2 is any type of 4.
study, calculation, or analysis:
Describe the nature of the study, calculation, A.
or analysis and identify any documents which discuss or describe the study, calculation, or analysis.
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B.
When and where was the study, calculation, or analysis performed?
C.
Identify the person [s] who performed the study, calculation, or analysis.
D.
Describe the results of each study, calculation, or analysis.
E.
Explain how such study, calculation, or analysis provides support for the basis.
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5.
If your answer to Interrogatory 2 is research:
A.
Describe all such research and identify each document discussing or describing such research.
B.
When and'where was the research. conducted?
C.
Identify the personis] who conducted the research.
D.
Explain how such research provides support for the basis.
6.
If your answer to Interrogatory 2 is conversations, consultations, correspondence, or any other type of communications with one or more individuals:
A.
Identify each such individual.
B.
State the educational and professional background of each such individual, including occupation and institutional affiliations.
C.
Describe the nature of each communication with each such individual, when it occurred,and identify all other individuals involved.
24' Describe the information received from each such D.
individual and explain how it provides support for the basis.
E.
Identify each letter, memorandum, tape, note, or other record related to each conversation, correspondence, or other communicatibh with'such individual.
At the evidentiary hearing in this proceeding, do 7.
Applicants intend to offer the testimony of any witnesses in opposition to the NRDC contentions as phrased and admitted by the Licensing Board-in-its Memorandum and Order of July 6, 1982?
If yes, A.
Identify each such witness.
State the educational and professional backgrorad B.
of each such witness, including occupation and institutional affiliations.
Specify the subject matter, by contention and C.
basis, upon which each such witness will testify.
At the evidentiary hearings in this proceeding, do 8.
Applicants intend to offer any documents into evidence in opposi-tion to the NRDC contentions as phrased and admitted by the Licensing Board in its Memorandum and Order of July 6, 19827 If yes, A.
Identify each such document.
Specify the subject matter, by contention and basis, B.
to which each such document relates.
C.
Identify the information in each such document which relates to the contention and basis.
D.
Explain how the information identified in Inter-rogatory 8.C provides support for Applicants' opposition to the contention.
9.
At the evidentiary hearings 1,n this proceeding, do Applicants intend to offer any evidence in opposition to the NRDC contentions that is not identified in your answer.to Interrogatories 7 or 8?
If yes, A.
Iden~ti'fy'the nature of each such evidence.
B.
Specify the subject matter, by contention and basis, to which each such evidence relates.
C.
Explain how such evidence provides support for the contention and basis.
DATED:
September 17, 1982 Respectfully submitted, Ralph Cavanagh Attorney for Natural Resources Defense Council, Inc.
25 Kearny Street
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San Francisco CA 94108 Phone: (415)421-6561 l
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